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contains several computational exceptions to application of the
addition to tax. Petitioner bears the burden of proving that he
paid estimated tax or that any of the exceptions excuse him from
paying estimated tax. See Rule 142(a). The addition to tax for
failure to pay estimated tax is mandatory, unless petitioner can
show that he qualifies for one of the exceptions. Grosshandler
v. Commissioner, 75 T.C. 1, 20-21 (1980) (citing Estate of Ruben
v. Commissioner, 33 T.C. 1071, 1072 (1960)).
Petitioner has failed to show that he paid estimated tax or
that any of the exceptions apply. Respondent’s determination of
additions to tax under section 6654(a) therefore is sustained.
C. Abatement of Interest
If, as part of a CDP Hearing, a taxpayer makes a request for
abatement of interest, the Court has jurisdiction over the
request for abatement of interest that is the subject of the
Commissioner’s collection activities. Katz v. Commissioner, 115
T.C. 329, 340-341 (2000). Generally, the Court considers only
arguments, issues, and other matters that were raised by the
taxpayer at the CDP Hearing or otherwise brought to the attention
of the Appeals Office. Magana v. Commissioner, 118 T.C. 488, 493
(2002); Miller v. Commissioner, 115 T.C. 582, 589 n.2 (2000),
affd. per curiam 21 Fed. Appx. 160 (4th Cir. 2001); Sego v.
Commissioner, 114 T.C. at 612.
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