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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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