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under the statute. See sec. 6654(a); Niedringhaus v.
Commissioner, 99 T.C. 202, 222 (1992).
The amount of the addition to tax under section 6654(a)
stated in the notice of deficiency is based on the return
respondent prepared for petitioner before the issuance of the
notice of deficiency. Nothing in the record indicates petitioner
made the required amount of estimated tax payments for taxable
year 2002. Petitioner has not shown that he falls within any of
the exceptions to the section 6654(a) addition to tax. See sec.
6654(e); Grosshandler v. Commissioner, 75 T.C. 1, 20-21 (1980).
Accordingly, we conclude petitioner is liable for the addition to
tax pursuant to section 6654(a) for taxable year 2002. Because
of respondent’s concession, the addition to tax applicable to
taxable year 2002 requires computation.
We have considered all of the other arguments made by the
parties, and, to the extent that we have not specifically
addressed them, we conclude they are without merit.
Reviewed and adopted as the report of the Small Tax Case
Division.
To reflect respondent’s concession and our resolution of
the disputed matters,
Decisions will be entered
under Rule 155.
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Last modified: May 25, 2011