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for additions to tax pursuant to section 6651(a)(1) and (2).
Section 6654 imposes an addition to tax for failure to pay
estimated income tax. Section 6654(e), however, provides that
the addition to tax pursuant to section 6654(a) shall not be
imposed when: (1) By reason of casualty, disaster, or other
unusual circumstances the imposition of such addition to tax
would be against equity and good conscience, or (2) when the
taxpayer became disabled in the taxable year for which estimated
payments were required to be made (or in the taxable year
preceding such year) and such underpayment was due to reasonable
cause and not willful neglect. Sec. 6654(e)(3)(A) and (B).
On the basis of the particular facts and circumstances
present in this case, namely petitioner’s severe health problems
and mental condition which incapacitated him during the years in
issue, we conclude that an exception provided in section 6654(e)
is applicable to Mr. Meyer for the years in issue. See Shaffer
v. Commissioner, supra. Accordingly, we conclude that Mr. Meyer
is not liable for the addition to tax pursuant to section 6654.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011