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Petitioner has failed to demonstrate that reasonable cause.
None of the stipulated facts directly addresses what caused
petitioner to come to any conclusion about the agreement, nor can
we infer from those facts what it was that caused her to come to
any conclusion. All we have in evidence is the agreement,
itself, which we have found to contradict petitioner’s
interpretation. We do not find the agreement to be ambiguous, so
that, without more (e.g., the opinion of counsel), we cannot
conclude that petitioner had reasonable cause for reaching the
interpretation she did.
We sustain respondent’s determination of the addition to tax
under section 6651(a) and the penalty under section 6662(a).
E. Section 6654
Respondent determined additions to tax under section 6654
(the section 6654 additions) for failure to pay estimated tax.
On brief, respondent states: “Petitioner underpaid her estimated
tax in both 1994 and 1995 because she erroneously failed to
report the payments from Mr. Mooney as pension income.
Therefore, she is liable for the * * * [section 6654 additions
to tax].”
Since petitioner filed returns for both years in issue,
section 6665(b) provides, in general, that the section 6654
additions are not treated as taxes for purposes of the deficiency
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