- 9 -
value for his labor. Misguided interpretations of the
Constitution or other typical tax protester arguments are not
reasonable cause. See Yoder v. Commissioner, T.C. Memo. 1990-
116. Accordingly, we hold that petitioner is liable for the
addition to tax under section 6651(a)(1) for taxable year 2000.
Section 6654(a) imposes an addition to tax for failure to
pay estimated income tax. Section 6654 applies where prepayments
of tax, either through withholdings or by making estimated
quarterly payments, do not equal the percentage of total
liability required under the statute, unless one of the several
statutory exceptions applies. Niedringhaus v. Commissioner, 99
T.C. 202, 222 (1992). The taxpayer bears the burden of showing
he qualifies for an exception. Habersham-Bey v. Commissioner, 78
T.C. 304, 319-320 (1982). We find that petitioner does not
qualify for any such exception. Accordingly, we hold that
petitioner is liable for the addition to tax under section 6654
for taxable year 2000.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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