Ronna Joan Robertson - Page 15




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          petitioner is liable for additions to tax under section                     
          6651(a)(1).                                                                 
               Section 6654(a) requires the imposition of an addition to              
          tax in the case of any underpayment of estimated tax by an                  
          individual.  See Estate of Ruben v. Commissioner, 33 T.C. 1071,             
          1072 (1960).  Section 6654(e) provides exceptions to the                    
          imposition of additions to tax under section 6654(a).  Petitioner           
          bears the burden of proving that one of these exceptions is                 
          applicable.  Petitioner introduced no evidence as to the                    
          applicability of the exceptions provided under section 6654(e).             
          Accordingly, petitioner is liable for the addition to tax under             
          section 6654(a).                                                            
               To reflect the foregoing,                                              

                                             Decision will be entered under           
                                        Rule 155.                                     





















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