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argument for relief from liability under section 6654 is that
they had reasonable cause for their failure to make estimated tax
payments under section 6654(a). With limited exceptions,24 “This
section has no provision relating to reasonable cause and lack of
willful neglect. It is mandatory and extenuating circumstances
are irrelevant.” Estate of Ruben v. Commissioner, 33 T.C. 1071,
1072 (1960); see also Grosshandler v. Commissioner, supra at 21.
In addition, Henry has offered no evidence that any of the
statutory exceptions under section 6654(e) apply. Accordingly,
respondent’s determination is sustained.
VI. Conclusion
We have carefully considered the remaining arguments of
petitioners for results contrary to those expressed herein and,
to the extent not discussed above, find those arguments to be
irrelevant, moot, or without merit.
To reflect the foregoing and concessions by the parties,
Decisions will be entered
under Rule 155.
24Sec. 6654(e)(3)(B) provides for an exception for newly
retired or disabled individuals where the taxpayer (1) either is
retired after having attained the age of 62 or became disabled in
the taxable year or the preceding taxable year in which the
estimated payments were required to be made, and (2) can
demonstrate that any underpayment was due to reasonable cause and
not to willful neglect. Sec. 6654(e)(3)(B) does not apply in
this case.
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