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find. Respondent’s evidence also shows that, for each of those
years, petitioner had sufficient income (above the exemption
amount) that he was required to file a return, and we so find.4
Petitioner’s only defense to the section 6651(a)(1) additions to
tax is that he was not required to file returns because his
income did not exceed the exemption amounts. We have found that,
for each year, petitioner’s income did exceed the year’s
exemption amount. Nor has petitioner introduced any evidence to
show that his mistaken beliefs were reasonable and free from
willful neglect. Petitioner is liable for the section 6651(a)(1)
additions to tax as computed by respondent.
2. Section 6654
Respondent’s evidence shows the following, which we find
accordingly: Petitioner filed a Federal income tax return for
1997 showing a liability of $3,803; he made no return for 1998;
his tax liability for 1998 is $16,067; he made two payments of
estimated tax for 1998, one on June 4, 1998, and the other on
September 24, 1998, each in the amount of $870; $126 was withheld
from his wages in 1998. Since 90 percent of petitioner’s tax
liability for 1998 ($14,460) is greater than his reported tax
liability for 1997 ($3,803), which is $1,937 greater than the sum
4 Sec. 6012(a) requires every individual having gross
income exceeding a certain minimum amount to file an income tax
return. Petitioner’s gross income exceeded the exemption amounts
of $2,700 and $2,750 for 1998 and 1999, respectively. See sec.
151(d); Rev. Proc. 97-57, sec. 3.08, 1997-2 C.B. 584, 586; Rev.
Proc. 98-61, sec. 3.08, 1998-2 C.B. 811, 815.
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