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1996. Furthermore, petitioner’s wife was available to assist
petitioner with his finances for at least a portion of the time,
and petitioner also had an accountant available who helped him
request the extensions of time to file. Consequently, while we
are sympathetic of petitioner’s situation, we find that he did
not have reasonable cause for failing to file timely his 1995 and
1996 Federal income tax returns and to pay the tax shown on the
1996 substitute return. We sustain respondent’s determination
that petitioner is liable for the additions to tax under section
6651(a)(1) and (2). The correct amounts of the additions to tax
must be calculated in the Rule 155 computations required in this
case.
We next address whether petitioner is liable for the section
6654(a) addition to tax for failure to make estimated Federal
income tax payments for 1995 and 1996. Unless the taxpayer
demonstrates that one of the statutory exceptions applies,
imposition of the section 6654(a) addition to tax is mandatory
where prepayments of tax, either through withholding or by making
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 (1992).
Petitioner did not address this issue separately from the
section 6651(a) issue. However, there is no “reasonable cause”
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