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tax return unless such failure is due to reasonable cause and not
due to willful neglect. Section 6654(a) imposes an addition to
tax for an individual taxpayer’s failure to pay estimated tax.
Petitioner acknowledges that his 1998 individual Federal
income tax return was not timely filed. The tax deficiency that
we have sustained herein, on the facts of this case, prima facie
establishes petitioner’s liability for the section 6654(a)
addition to tax for failure to pay estimated tax. The evidence
herein does not establish petitioner’s entitlement to any
exception to these additions to tax. See Mendes v. Commissioner,
121 T.C. 308, 324-325 (2003).
Petitioner is liable for the additions to tax under sections
6651(a)(1) and 6654(a).4
We have considered all arguments made herein, and, to the
extent not addressed, we conclude that they are without merit or
are irrelevant.
To reflect the foregoing,
Decision will be entered
under Rule 155.
4 Respondent has conceded the sec. 6651(a)(2) addition to
tax that was asserted against petitioner.
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