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willful neglect. “Reasonable cause” contemplates that the
taxpayer exercised ordinary business care and prudence in
providing for payment of the taxpayer’s tax liability and was
nonetheless unable to pay the tax or would suffer an undue
hardship if the tax were paid within the prescribed time. Sec.
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 paid only a relatively small
portion of his tax liability for 1996 and failed to pay any of
his tax liability for 1997. Petitioner offered no evidence
whatsoever that would support a finding that his failure to pay
was due to reasonable cause and not willful neglect.
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 notices of deficiency.
E. Additions 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
during the course of the taxable year, do not equal the
percentage of total liability required under the statute. See
sec. 6654(a); Niedringhaus v. Commissioner, 99 T.C. 202, 222
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