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did not file a tax return for 2001. Therefore, the Court
concludes that petitioner had a required annual payment for 2001,
pursuant to the parenthetical language in section
6654(d)(1)(B)(i).
The section 6654 addition to tax is mandatory unless
petitioner can place himself within one of the computational
exceptions provided by section 6654(e). See Recklitis v.
Commissioner, 91 T.C. 874, 913 (1988); Grosshandler v.
Commissioner, 75 T.C. 1, 20-21 (1980). There is no exception for
reasonable cause or lack of willful neglect. Estate of Ruben v.
Commissioner, 33 T.C. 1071, 1072 (1960).
Petitioner has not shown that any of the statutory
exceptions under section 6654(e) applies. Respondent's
determination as to the addition to tax under section 6654(a) is
sustained.
Respondent’s determinations are sustained except to the
extent of concessions made.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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Last modified: November 10, 2007