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application of other allowable credits). Sec. 6654(f); see sec.
31. Except in very limited circumstances not applicable to this
case, see sec. 6654(e)(3)(B), section 6654 provides no exception
for reasonable cause or lack of willful neglect.
There are two mechanical exceptions to the applicability of
the section 6654 addition to tax. First, as relevant to this
case, the addition is not applicable if the tax shown on the
individual’s return for the year in question (or, if no return is
filed, the individual’s tax for that year), reduced for these
purposes by any allowable credit for wage withholding, is less
than $500.13 Sec. 6654(e)(1). Second, the addition is not
applicable if the individual’s tax for the preceding taxable year
was zero. Sec. 6654(e)(2).
Petitioner argues that he “cannot be held liable for failing
to file an estimated tax return because the Petitioner did not
owe any taxes”. Respondent’s deficiency determination for the
audit year, which we sustain in full herein, shows that, contrary
to petitioner’s argument, petitioner did, in fact, owe taxes for
the audit year. That does not dispose of the matter, however.
There remains the issue of whether petitioner may rely on having
satisfied the requirement of section 6654(d)(1)(A) and (B) that
the amount of each of his estimated tax installments for the
13 Effective for taxable years beginning after Dec. 31,
1997, the threshold amount is $1,000. Taxpayer Relief Act of
1997, Pub. L. 105-34, sec. 1202(a), 111 Stat. 994.
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