Richard Mark Hansen - Page 13

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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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