- 15 - to file returns. Our determinations with respect to fraud, however, necessarily reject any argument that the failure to file returns was due to reasonable cause or that the underpayments of tax were not at least due to negligence. Section 6654 Addition to Tax Respondent also determined that petitioner is liable for the addition to tax under section 6654 for the years in issue. Section 6654 provides an addition to tax for failure to make timely and sufficient payments of estimated tax. Petitioner argues that, because he did not have taxable income for any of the years in issue, he was not required to pay estimated taxes. We have determined, however, that petitioner had taxable income during the years in issue. The section 6654 addition to tax is mandatory unless petitioner can place himself within one of the computational exceptions provided by section 6654. Grosshandler v. Commissioner, 75 T.C. 1, 20-21 (1980). None of the exceptions of section 6654(d) for 1982, 1983, and 1984, or section 6654(e) for 1985 and 1986, apply in this instance. Petitioner has further asserted that the imposition of this addition to tax would be inequitable in this case because he had an "honest" belief that he did not have taxable income during the years in issue. "This section has no provision relating to reasonable cause and lack of willful neglect. It is mandatory and extenuating circumstances are irrelevant." Estate of RubenPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
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