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857 (3d Cir. 1973); Reiff v. Commissioner, 77 T.C. 1169, 1177,
1180 (1981).
Accordingly, we sustain respondent’s determination under
section 6651(a)(1) for the taxable years in issue.
3. Addition to Tax Under Section 6654(a)
Respondent further determined an addition to tax under
section 6654(a) for each of the years in issue, asserting that
petitioner failed to pay estimated tax. Section 6654(a)
provides for an addition to tax “in the case of any underpayment
of estimated tax by an individual”. Estimated income tax
payments are used to provide for current payment of income taxes
not collected through withholding. Generally, this addition to
tax is mandatory, and there is no exception for reasonable cause.
See Recklitis v. Commissioner, 91 T.C. 874, 913 (1988);
Grosshandler v. Commissioner, 75 T.C. 1, 20-21 (1980). However,
no addition to tax is imposed if one of the exceptions contained
in section 6654 is met. See Recklitis v. Commissioner, supra at
913.
Petitioner has offered no evidence to show that any of the
statutory exceptions apply. Accordingly, we sustain respondent’s
determination under section 6654(a) for the taxable years in
issue.
We have reviewed petitioner’s other arguments and find them
to be irrelevant or without merit.
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