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301.6651-1(c)(1), Proced. & Admin. Regs. “Willful neglect” means
a conscious, intentional failure or reckless indifference.
United States v. Boyle, supra at 245.
In the present case, petitioner failed to pay his tax
liability for either 1996 or 1997. Petitioner’s professed belief
that he is not a taxpayer within the scope of the Internal
Revenue Code does not, as a matter of law, constitute reasonable
cause for petitioner’s failure to pay his tax liabilities. See
Rowlee v. Commissioner, supra; Ebert v. Commissioner, supra.
In view of the foregoing, we hold that petitioner is liable
for the additions to tax under section 6651(a)(2) as determined
by respondent in the notice of deficiency.
D. Addition to Tax for Failure To Pay Estimated Tax
Section 6654 imposes an addition to tax for failure to pay
estimated tax. As applicable herein, imposition of the addition
is mandatory whenever prepayments of tax, either through
withholding or the making of estimated quarterly tax payments, do
not equal the percentage of total liability required under the
statute. See sec. 6654(a); Niedringhaus v. Commissioner, 99 T.C.
202, 222 (1992); Grosshandler v. Commissioner, 75 T.C. 1, 20-21
(1980). Thus, in the present case, we need not address any issue
relating to reasonable cause and lack of willful neglect;
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