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and O. Toole. Petitioner contends that his failure to report
those amounts in income was due to reasonable cause. We
disagree.
It should have been obvious to petitioner that the amounts
were taxable to him because his Social Security number appears on
the Forms 1099, 1098, and W-2. Petitioner has not shown that his
failure to file was due to reasonable cause and not willful
neglect.
D. Whether Petitioner Is Liable for the Addition to Tax for
Failure To Pay Estimated Tax
Respondent determined that petitioner is liable for the
addition to tax under section 6654 for failure to pay estimated
tax for the years in issue. We have jurisdiction to review this
determination because petitioner did not file a return for any of
the years in issue. Sec. 6665(b)(2); Meyer v. Commissioner, 97
T.C. 555, 562 (1991). A taxpayer is liable for the addition to
tax for failure to pay estimated tax unless the taxpayer shows
that he or she meets one of the exceptions provided in section
6654(e), none of which apply here.
Petitioner contends that he had deposited enough money to
pay any tax liability he may have for 1993, 1994, 1995, 1996, and
1997. He contends that he maintained a $5,000 “‘estimated tax
applied’ fund” with respondent and that the dividends he received
were subject to “31% backup tax” withholding. However,
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