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petitioner shows that a statutory exception applies, imposition
of the addition to tax under section 6654(a) is automatic where
payments of tax, either through withholding or by making
estimated quarterly tax payments during the course of the year,
do not equal the percentage of total liability required under the
statute. See Niedringhaus v. Commissioner, 99 T.C. 202, 222
(1992); Recklitis v. Commissioner, 91 T.C. 874, 913 (1988);
Grosshandler v. Commissioner, 75 T.C. 1, 20-21 (1980).
Petitioner has offered no evidence to show that any of the
statutory exceptions apply. Accordingly, we sustain respondent's
determination that petitioner is liable for the addition to tax
under section 6654(a) for the year in issue.
We have carefully considered all remaining arguments made by
petitioner for a result contrary to that expressed herein, and,
to the extent not discussed above, find them to be irrelevant,
moot, or without merit.
To reflect the foregoing,
Decision will be entered
for respondent.
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