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estopped, by its failure to respond within 30 days to his letter,
from arguing that he is liable for income tax is also frivolous
and does not excuse his failure to file his 1998 return. We
conclude that petitioner is liable for the addition to tax under
section 6651(a) for failure to file for 1998.
3. Failure To Pay Estimated Tax Under Section 6654(a)
Respondent determined that petitioner is liable for the
addition to tax under section 6654(a) for failure to pay
estimated tax for 1998. We have jurisdiction to review this
determination because petitioner did not file a return for 1998.
Sec. 6665(b)(2); Meyer v. Commissioner, 97 T.C. 555, 562 (1991).
To be liable for the addition to tax under section 6654, a
taxpayer must have underpaid or failed to pay estimated tax for
the year in issue. Sec. 6654(a). A taxpayer is liable for the
addition to tax for failure to pay estimated tax unless he or she
meets one of the exceptions provided in section 6654(e), none of
which applies here.
Petitioner alleged in the petition that all of respondent’s
adjustments were wrong, but he offered no evidence and made no
argument directed specifically to his liability for the section
6654 addition to tax. We conclude that petitioner is liable for
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