- 6 - jurisdiction to decide this case; and (3) an income tax violates the Sixteenth Amendment because it is an impermissible "direct tax". We see no need to fully describe each of petitioner's constitutional arguments or to address them individually. To do so might imply that the arguments have some colorable merit when in fact they are groundless. It is sufficient to note that petitioner readily acknowledges that he received income yet refuses to pay tax on it. Accordingly, we hold that petitioner is liable for the deficiencies determined by respondent. Respondent determined additions to tax under sections 6651(a)(1) and 6654. Section 6651(a)(1) imposes an addition to tax for failure to file a timely return unless it is shown that such failure to file was due to reasonable cause and not due to willful neglect. Petitioner bears the burden of proving that he had reasonable cause for failing to file tax returns for the years in issue. Rule 142(a); Larsen v. Commissioner, 765 F.2d 939, 941 (9th Cir. 1985). Petitioner's tax protester rhetoric does not establish reasonable cause. Accordingly, we hold that petitioner is liable for additions to tax under section 6651(a)(1). Section 6654(a) generally imposes an addition to tax if the total tax withheld and any estimated tax payments made during a year do not equal or exceed the threshold set forth in sectionPage: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011