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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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