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Petitioner did not file Federal income tax returns or
applications for extensions of time to file for 1990, 1994, or
1996. Petitioner stated in his petition that he was not liable
for penalties as determined by respondent. The record is devoid
of any evidence establishing a reasonable cause for his failure
to file a return; thus, we hold petitioner is liable for the
section 6651(a)(1) addition to tax.
IV. Section 6654(a) Addition to Tax
Section 6654(a) imposes an addition to tax in the case of
any underpayment of estimated tax by an individual. Unless a
statutory exception applies, the addition to tax under section
6654(a) is mandatory. See sec. 6654(a), (e); Recklitis v.
Commissioner, 91 T.C. 874, 913 (1988); Grosshandler v.
Commissioner, 75 T.C. 1, 20-21 (1980); Estate of Ruben v.
Commissioner, 33 T.C. 1071, 1072 (1960) (“This section has no
provision relating to reasonable cause and lack of willful
neglect. It is mandatory and extenuating circumstances are
irrelevant.”). None of the statutory exceptions under section
6654(e) applies in this case. Petitioner stated in his petition
that he was not liable for penalties as determined by respondent,
but presented no further argument regarding payments of estimated
tax. We thus hold petitioner liable for the section 6654(a)
addition to tax.
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