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VIII. Whether Petitioner Is Liable for the Addition to Tax Under
Section 6654(a) for the Years at Issue
Respondent also determined additions to tax for 1989 through
1992 under section 6654 arising from an underpayment of estimated
taxes. This addition to tax is mandatory absent a showing by
petitioner that one of the specified statutory exceptions
applies. See Clayton v. Commissioner, supra (citing Grosshandler
v. Commissioner, 75 T.C. 1, 20-21 (1980)). Petitioner has made
no such showing for her 1989 and 1990 taxable years, and we
therefore sustain the additions to tax provided in section 6654
for those years. Section 6654(e) provides, however, that no
addition to tax for underpaid estimated taxes shall be imposed if
the tax “is less than $500.” We have found that petitioner is
not liable for income tax for the years 1991 and 1992.
Accordingly, the determination of additions to tax under section
6654 for those 2 years is not sustained.
In view of the foregoing,
Decision will be entered
under Rule 155.
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