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III. Additions to Tax for Failure To Pay Estimated Tax
For 1988, 1989, 1990, 1991, and 1992, respondent determined
additions to tax for failure to pay estimated tax under section
6654. If there is an underpayment of estimated tax for any of
the years in issue, section 6654(a) imposes an addition to tax
equal to the interest rate established under section 6621 applied
to the amount of the underpayment for the period of the
underpayment. This addition to tax is mandatory and, unless one
of the exceptions in section 6654(e) applies, is imposed
regardless of reasonable cause or extenuating circumstances. See
Dodge v. Commissioner, 96 T.C. 172, 183 (1991), affd. on this
issue 981 F.2d 350 (8th Cir. 1992); Grosshandler v. Commissioner,
75 T.C. 1, 21 (1980).
The Commissioner’s determinations of additions to tax under
section 6654 are presumed to be correct, and the taxpayer bears
the burden of proving that he is not liable for those additions.
See Rule 142(a). Petitioner did not offer any evidence that he
paid estimated tax for 1988, 1989, 1990, 1991, and 1992.
Accordingly, we sustain respondent’s determination.
IV. Penalty Pursuant to Section 6673
Under section 6673, this Court may award a penalty to the
United States of up to $25,000 when the proceeding has been
instituted or maintained by the taxpayer primarily for delay or
if the taxpayer's position in such proceeding is frivolous or
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