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didn’t get turned in.” Although petitioner may have had numerous
concerns or problems, simply neglecting or forgetting to file his
Federal tax return does not amount to “reasonable cause”. See
sec. 6651(a)(1); United States v. Boyle, supra at 246.
Respondent is, therefore, sustained on this issue.
Respondent also determined a section 6654 addition to tax
against petitioner. A taxpayer is subject to this addition to
tax “in the case of any underpayment of estimated tax by an
individual”. Sec. 6654. Subject to certain statutory
exceptions, the addition to tax is automatically applied if the
amounts of withholding and estimated tax payments do not equal
statutorily designated amounts. Niedringhaus v. Commissioner, 99
T.C. 202, 222 (1992).
The statute, however, provides an exception to this
automatic imposition where the preceding taxable year was 12
months, the taxpayer did not have any liability for tax for such
year, and the taxpayer was a citizen or resident of the United
States throughout the preceding taxable year. Sec. 6654(e)(2).
Petitioner is a U.S. citizen and had no income tax liability for
the 1997 taxable year. Petitioner’s liability for the 1998
taxable year was not due to insufficient withholdings by his
employers, as respondent alleges, but due solely to the tax due
on a one-time early withdrawal from his retirement fund.
Petitioner falls within the stated exception in section
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