John B. Mathers, Sr. - Page 15

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          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 Ruben             

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