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The record demonstrates that petitioner was well aware of
his obligation to file an income tax return but chose not to do
so in pursuit of what can only be regarded as a protest against
the Federal income tax. In our view, petitioner’s failure to
file was willful.
In view of the foregoing, we hold that petitioner is liable
for the addition to tax under section 6651(a)(1). Respondent’s
determination in this regard, modified as to amount, see supra
note 1, is sustained.
D. Addition to Tax for Failure To Pay Estimated Tax
Petitioner contends that he is not liable for the addition
to tax under section 6654(a). We disagree; petitioner’s
contention is wrong, and it is frivolous in the context of this
case.
Section 6654 imposes an addition to tax for failure to pay
estimated tax. As applicable herein, imposition of the addition
is mandatory whenever prepayments of tax, either through
withholding or the making of 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); Grosshandler v. Commissioner, 75 T.C. 1, 20-21 (1980).
Thus, in the present case, we need not address any issue relating
to reasonable cause and lack of willful neglect; extenuating
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