Douglas L. Hadsell - Page 19




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               It is undisputed that petitioner received both unemployment               
          compensation and compensation as an independent contractor for                 
          the years at issue and failed to make estimated tax payments.                  
               Upon the basis of the record, petitioner does not qualify                 
          for any of the exceptions listed in section 6654(e).  Therefore,               
          we hold that he is liable for the additions to tax pursuant to                 
          section 6654(a) for the 1988, 1989, and 1990 taxable years.                    
          Respondent is sustained on this issue.                                         
               To reflect the foregoing,                                                 
                                              Decision will be entered                  
                                        under Rule 155.                                 




























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