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facts and circumstances surrounding his failure to pay respondent
until November 2002, we do not believe the foregoing arrangements
constitute the exercise of ordinary business care and prudence.
Thus, petitioner has not shown that his failure to make timely
payment of $32,157 of his 2000 income tax liability is due to
reasonable cause. We accordingly hold that petitioner is liable
for an addition to tax under section 6651(a)(2).6
Section 6654 Addition to Tax
Section 6654(a) imposes an addition to tax for failure to
pay estimated income tax where prepayments of such tax, either
through withholding or by making estimated quarterly tax payments
during the course of the year, do not equal the percentage of
total liability required under the statute, unless the taxpayer
shows that one of the statutory exceptions applies. Sec.
6654(a); Niedringhaus v. Commissioner, 99 T.C. 202, 222 (1992).
The amount required to be paid through each such estimated
quarterly payment is 25 percent of the "required annual payment".
Sec. 6654(d)(1)(A). The "required annual payment" is, in turn,
the lesser of 90 percent of the tax shown on the return for that
6 We suggested above that there might have been reasonable
cause for the failure to pay during some period before petitioner
was sent reasonable notice, by virtue of the State of Missouri's
refund check, that his estimated tax payment had been
misdirected. However, petitioner, who has the burden to show
reasonable cause, has not established when in 2001 the refund
check was sent. We therefore have no basis on which to demarcate
the period for which there may have been reasonable cause.
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