Christopher Richardson - Page 10

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          substantial authority.  Higbee v. Commissioner, 116 T.C. 438, 446           
          (2001); H. Conf. Rept. 105-599, supra at 241, 1998-3 C.B. at 995.           
               Petitioner did not file returns for 1998-2001, and he did              
          not make estimated tax payments with respect to his tax liability           
          for those years.  There is no evidence that petitioner paid any             
          tax for the years in issue.  Thus, respondent has met the burden            
          of production, and petitioner is liable for additions to tax for            
          failure to file under section 6651(a)(1) of $1,241.55 for 1998,             
          $1,144.80 for 1999, $798.08 for 2000, and $992.25 for 2001, and             
          additions to tax under section 6654 for failure to pay estimated            
          tax of $250.45 for 1998, $244.35 for 1999, $190.77 for 2000, and            
          $174.52 for 2001.                                                           
               To reflect the foregoing,                                              

                                                       Decision will be               
                                                  entered for respondent.             




















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