Antonio B. Secapure - Page 10

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          burden of proving that his failure to file was due to reasonable            
          cause and not willful neglect.  See United States v. Boyle,                 
          supra.                                                                      
               Petitioner did not offer evidence showing that he had                  
          reasonable cause for not filing his 1995 return.  We conclude               
          that petitioner is liable for the addition to tax under section             
          6651(a)(1) for failure to file his 1995 income tax return.                  
          C.   Whether Petitioner Is Liable for the Addition to Tax for               
               Failure To Pay Estimated Tax                                           
               Respondent determined that petitioner is liable for the                
          addition to tax under section 6654 for failure to pay estimated             
          tax for 1995.  We have jurisdiction to review this determination            
          because petitioner did not file a return for 1995.  Sec.                    
          6665(b)(2); Meyer v. Commissioner, 97 T.C. 555, 562 (1991).                 
               To be liable for the addition to tax under section 6654, a             
          taxpayer must have underpaid or failed to pay estimated tax for             
          the year in issue.  Sec. 6654(a).  A taxpayer is liable for the             
          addition to tax for failure to pay estimated tax unless the                 
          taxpayer shows that he or she meets one of the exceptions                   
          provided in section 6654(e), none of which apply here.                      
               Brown reviewed respondent’s administrative file in this                
          case, and testified that petitioner made no tax payments for                










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