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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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Last modified: May 25, 2011