Richard P. Kringen - Page 10




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          file and pay for each year in issue was due to reasonable cause             
          and not due to willful neglect.  Accordingly, we sustain the                
          determinations of respondent with respect to the section                    
          6651(a)(1) and (2) additions to tax.  We further sustain                    
          respondent’s assertion of increased deficiencies under section              
          6651(a)(2) for the years 1996, 1997, and 1998.  Lopez v.                    
          Commissioner, T.C. Memo. 2001-93.                                           
               Subject to exceptions that do not apply in this case,                  
          section 6654(a) provides for an addition to tax “in the case of             
          any underpayment of estimated tax by an individual”.  Although              
          required to do so, petitioner made no estimated tax payments                
          during any year in issue.  Therefore, respondent’s imposition of            
          the addition to tax under section 6654(a) for each year in issue            
          is sustained.                                                               
               Reviewed and adopted as the report of the Small Tax Case               
          Division.                                                                   


                                                  Decision will be entered            
                                             for respondent.                          















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