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sec. 6012(a). Petitioner has alleged, and the record suggests,
no reasonable cause for his failure to do so. To the contrary,
petitioner’s conduct in this proceeding and his chronic failures
to file tax returns convince us that these failures were
intentional and not due to reasonable cause. Accordingly, we
conclude and hold that petitioner is liable for section
6651(a)(1) additions to tax as determined in the notice of
deficiency and as asserted in respondent’s amended answer.8
2. Failure To Pay Estimated Tax
Section 6654 imposes an addition to tax for underpaying
estimated tax. Sec. 6654(a). The section 6654 addition to tax
is mandatory unless the taxpayer comes within one of the limited
statutory exceptions. See Recklitis v. Commissioner, 91 T.C.
874, 913 (1988).
Respondent alleges that petitioner failed to make required
estimated tax payments with respect to nonemployee compensation
that he received during the years at issue. Petitioner has not
specifically denied this allegation; at trial he merely stated
that “My recollection and records [make] it very difficult * * *
8 In his reply to respondent’s amended answer, petitioner
alleges without elaboration that respondent miscalculated the
amount of the sec. 6651(a)(1) addition to tax. Petitioner did
not raise this issue at trial or on brief; therefore, we deem
petitioner to have conceded it. See Burbage v. Commissioner, 82
T.C. 546, 547 n.2 (1984), affd. 744 F.2d 644 (4th Cir. 1985);
Wolf v. Commissioner, T.C. Memo. 1992-432, affd. 13 F.3d 189 (6th
Cir. 1993).
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