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taxable year or 100 percent of the tax shown on the return of the
individual for the preceding taxable year (110 percent for
individuals with adjusted gross income exceeding $150,000). Sec.
6654(d)(1)(B) and (C).
Section 6654 is essentially an interest charge on the amount
by which a taxpayer underpays his or her estimated tax, until the
earlier of the estimated tax's being paid or the due date of the
return. S. Rept. 1622, 83d Cong., 2d Sess. 592 (1954); see also
Bittker & Lokken, Federal Taxation of Income, Estates & Gifts,
par. 111.5.6., at 111-135 (2d ed. 1992) (noting that section 6654
causes underpayments of estimated tax to effectively bear
interest). There is no broadly applicable reasonable cause
exception to the section 6654 addition to tax; in general, it is
mandatory, and extenuating circumstances are irrelevant. Estate
of Ruben v. Commissioner, 33 T.C. 1071, 1072 (1960); see also
Grosshandler v. Commissioner, 75 T.C. 1, 20-21 (1980) (imposition
of section 6654 addition to tax is mandatory where estimated
payments do not equal statutorily required percentage).
Respondent likewise bears the burden of production regarding
the section 6654 addition to tax. Sec. 7491(c); Higbee v.
Commissioner, 116 T.C. 438 (2001). It is undisputed that the tax
shown on petitioner's 2000 return was $119,849, that petitioner's
estimated tax payments for 2000 totaled $64,314, and that
petitioner's June 2000 estimated tax payment of $32,157 was not
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