- 34 -
and extenuating circumstances are irrelevant.” Estate of Ruben
v. Commissioner, 33 T.C. 1071, 1072 (1960); see also Grosshandler
v. Commissioner, supra at 21. None of the statutory exceptions
under section 6654(e) applies in this case.
Petitioner concedes that as of the date the statutory
notice of deficiency was mailed to him, he had not made any
estimated tax payments for 1990, 1991, 1993, and 1994.
Petitioner did not present any argument on this issue; therefore,
the issue is deemed conceded. Respondent’s determination is
sustained.
We have carefully considered the remaining arguments of both
parties 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 the concessions of the parties,
Decision will be entered
under Rule 155.
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