Charles H. Little III - Page 8

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          return for the year at issue.  Although additions to tax were               
          abated for petitioner’s prior years, the Court sees no basis for            
          an abatement for the year at issue.  The Court, moreover, has no            
          obligation to abate the additions to tax simply because they were           
          abated for prior years.  Respondent is sustained on this issue.             
               The final issue is respondent’s determination that                     
          petitioner is liable for the addition to tax under section                  
          6654(a) for failure to pay estimated tax.  This addition to tax             
          is applicable where there is an underpayment of estimated tax,              
          subject to exceptions or waivers that are not applicable here.              
          Sec. 6654(e).  The provisions of this section are mandatory where           
          there is an underpayment of tax as determined under section 6654.           
          This section contains no exonerating provisions, such as                    
          reasonable cause or lack of willful neglect.  Estate of Ruben v.            
          Commissioner, 33 T.C. 1071, 1072 (1960).  In general, estimated             
          income tax payments are used to provide for payment of income               
          taxes not collected through withholding.  Section 6654(c)                   
          provides for quarterly installments.  Income taxes withheld from            
          salaries or wages apply toward the amount of each required                  
          quarterly installment; however, to the extent withholdings do not           
          satisfy the required quarterly installments, the taxpayer is                
          required to make supplemental quarterly payments of estimated               
          taxes.  Sec. 6654(f).  Since petitioner was self-employed, he was           
          required to make estimated payments.  He did not make estimated             

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