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he would have suffered substantial loss if he had paid his taxes
by the due date. We also observe that adverse economic
conditions do not necessarily constitute reasonable cause because
almost every nonwillful failure to pay taxes is the result of
financial difficulties. See Wolfe v. United States, 612 F.Supp.
605, 607-608 (D. Mont. 1985), affd. on other grounds 798 F.2d
1241 (9th Cir. 1986).
We therefore conclude that petitioner failed to demonstrate
that his failure to timely pay tax shown on his returns was due
to reasonable cause and not willful neglect. See sec. 301.6651-
1(c), Proced. & Admin. Regs.; sec. 1.6161-1(b), Income Tax Regs.
Accordingly, petitioner is liable for the additions to tax under
section 6651(a)(2) for the years in issue.
We next address the addition to tax under section 6654 for
the taxable year 2001. Section 6654(a) imposes an addition to
tax for failure to make timely estimated income tax payments.
Section 6654(e) contains several computational exceptions to
application of the addition to tax. As relevant herein, there is
no addition to tax under section 6654(a) if the tax shown on the
return is less than $1,000, sec. 6654(e)(1), or the taxpayer did
not have any liability for tax for the preceding taxable year,
sec. 6654(e)(2).
Petitioner bears the burden of proving that he paid
estimated tax or that any of the exceptions excuse him from
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