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standing alone, does not bar a finding of fraud. See Edelson v.
Commissioner, 829 F.2d 828 (9th Cir. 1987), affg. T.C. Memo.
1986-223. We find that petitioner knew of his obligation to pay
tax and intentionally evaded the tax known to be owing by failing
to report his income. Consequently, we sustain respondent's
determination of the applicability of the fraud additions to tax
for each of the years 1986, 1987, 1988, and 1989. For 1986,
1987, and 1988, petitioner has not established any portion of the
underpayment is not attributable to fraud.
4. Addition to Tax for Failure To Pay Estimated Tax Under
Section 6654 for the Years 1987-95
Respondent determined that petitioner is liable for an
addition to tax for failure to pay estimated income tax under
section 6654(a) for the years 1987-1995. Unless the taxpayer
demonstrates that one of the statutory exceptions applies,
imposition of this addition to tax is mandatory where prepayments
of tax, either through withholding or by making estimated
quarterly tax payments during the course of the taxable year, do
not equal the percentage of total liability required under the
statute. See sec. 6654(a); Niedringhaus v. Commissioner, 99 T.C.
202, 222 (1992); Grosshandler v. Commissioner, 75 T.C. 1, 20-21
(1980). Petitioner bears the burden of proving his entitlement
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