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calculations. In determining the number of days, petitioner
incorrectly failed to include the day of entry into the United
States and the day of departure from the United States.
On the basis of the record before us, we conclude that
petitioner meets the substantial presence test for both years in
issue; accordingly, petitioner is deemed a U.S. resident alien for
1993 and 1994 and is subject to U.S. tax on the compensation he
received.
We now turn our attention to whether petitioner is liable for
the section 6654 addition to tax for the years in issue. The
section 6654 addition is imposed on an individual taxpayer who fails
to make timely payments of estimated tax. An underpayment of
estimated tax exists if a tax payment for any of the four
installment period due dates (usually quarterly) is less than the
amount of taxes required to be paid each installment. See sec.
6654(b)(1). The amount of the addition is determined by applying
the applicable interest rate to the amount of the underpayment for
the period of time that the underpayment exists. See sec. 6654(a).
Petitioner failed to make any estimated tax payments in 1993
and 1994, and he does not qualify for any exception to the section
6654 addition to tax. Consequently, he is liable for the section
6654 addition to tax for both years as determined by respondent.
In reaching our holdings, we have considered all of the
arguments petitioner presented for contrary holdings (including
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