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Nevertheless, we need not decide whether the alleged abuse
of petitioner’s children and the ensuing turmoil it created in
petitioner’s life were sufficient to establish reasonable cause
for his untimely filing and payment of tax. In a sworn affidavit
made in 1999 in connection with his request for temporary
physical custody of his sons, petitioner declared that he did not
become aware of the alleged abuse until the summer of 1999. In
light of this admission, it is clear that the alleged abuse
played no role in petitioner’s failure to file returns timely and
pay tax for 1996 through 1998. By the time the abuse was
discovered, according to petitioner’s own documentation, the 1996
return was more than 2 years late, the 1997 return was 1 year
late, and the 1998 return was overdue. Thus, when the event on
which petitioner relies occurred, he already had established a
pattern of failing to file the tax returns and pay the tax here
in issue for reasons other than the alleged abuse of his sons.
We are not convinced that the reasons for petitioner’s failure to
file or pay taxes changed after mid-1999. Accordingly, we hold
that petitioner is liable for the additions to tax under section
6651(a)(1) and (2) for the years at issue.
The next issue for decision is whether petitioner is liable
for a section 6654(a) addition to tax for underpayment of
estimated tax for the years at issue. Section 6654(a) provides
that in the case of an underpayment of estimated tax by an
individual there shall be added to the tax an amount determined
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