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exception for the section 6654(a) addition to tax similar to that
for the section 6651(a) additions to tax. Nothing in the record
indicates petitioner made the required amount of estimated tax
payments for taxable years 1995 and 1996, and petitioner does not
argue, and the record does not indicate, that any of the
statutory exceptions apply. We sustain respondent’s
determination that petitioner is liable for the additions to tax
under section 6654(a). The applicability of the additions to tax
after concessions, and the correct amounts thereof, must be
calculated in the Rule 155 computations required in this case.
Reviewed and adopted as the report of the Small Tax Case
Division.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011