- 31 -
to any exception. See Habersham-Bey v. Commissioner, 78 T.C.
304, 319-320 (1982).
Petitioner has not filed returns for the years in issue or
made any estimated tax payments for those years, nor has he shown
that any of the statutory exceptions are applicable in this case.
We, therefore, sustain respondent's determination.
Decision will be entered
under Rule 155.
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