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exercised ordinary business care and prudence. United States v.
Boyle, 469 U.S. 241, 246 (1985). Willful neglect is defined as a
"conscious, intentional failure or reckless indifference." Id.
at 245.
Petitioner admitted that he did not file a tax return for
1996, and he did not provide any reason for his failure to file.
Because petitioner presented no reasonable cause for his failure
to file, we sustain respondent’s determination of the addition to
tax under section 6651(a)(1).
Because the 1995 tax return was timely filed, we do not have
jurisdiction over the section 6654 addition to tax for 1995.
Fujita v. Commissioner, T.C. Memo. 1999-164.
We now consider whether petitioner is liable for the
addition to tax under section 6654 for the failure to pay
estimated taxes for 1996. Section 6654(c) imposes a requirement
that estimated taxes be paid in installments. If a taxpayer
fails to pay a sufficient amount of estimated taxes, section
6654(a) provides for a mandatory addition to tax in the absence
of exceptions not applicable here. Grosshandler v. Commissioner,
75 T.C. 1, 20-21 (1980). Petitioner failed to pay estimated
taxes in 1996, and no Federal income tax was withheld from his
income. Accordingly, petitioner is liable for the addition to
tax under section 6654 for the 1996 taxable year.
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