Dennis E. Runkle and Debra A. Runkle - Page 37

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          deduct any insurance-related expenses in excess of those allowed            
          by respondent in the deficiency notice.                                     
          C.  Estimated Tax Addition                                                  
               Respondent also determined each petitioner was liable for an           
          addition to tax under section 6654(a) for failure to make                   
          estimated tax payments for each of the years at issue.  Section             
          6654(a) provides for an addition to tax where an individual                 
          underpays estimated tax.  The estimated tax addition is mandatory           
          unless a statutory exception in section 6654(e) applies.  See               
          Recklitis v. Commissioner, 91 T.C. at 913; Grosshandler v.                  
          Commissioner, 75 T.C. at 20-21; see also Estate of Ruben v.                 
          Commissioner, 33 T.C. 1071, 1072 (1960) (reasonable cause and               
          lack of willful neglect are not relevant considerations for                 
          estimated tax addition).                                                    
               The record reflects that Mr. Runkle made one estimated tax             
          payment of $1,987 towards his tax liability for 1991, and since             
          that payment in April 1991, neither petitioner has made any other           
          estimated tax payments for the years at issue.  Petitioners                 
          failed to present any evidence to contradict respondent’s                   
          determination, and none of the statutory exceptions under section           
          6654(e) applies.  We therefore find that petitioners are liable             

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