James Luther Cochrane - Page 20

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          however, if the taxpayer shows that there was substantial                   
          authority for his treatment of an item, or that the relevant                
          facts affecting the tax treatment of the item are adequately                
          disclosed on the return or in a separate statement attached to              
          the return.  Sec. 6661(b)(2)(B).  Petitioner bears the burden of            
          proof.  Rule 142(a); Hall v. Commissioner, 729 F.2d 632, 635 (9th           
          Cir. 1984), affg. T.C. Memo. 1982-337.                                      
               Petitioner has failed to offer any evidence on this issue,             
          and we sustain respondent's determination.                                  

          Addition to Tax for Failure To Pay Estimated Tax Under Section              
          6654 in 1986                                                                

               Respondent determined that petitioner is liable for an                 
          addition to tax for failure to pay estimated income tax under               
          section 6654(a) for 1986.  Unless the taxpayer demonstrates that            
          one of the statutory exceptions applies, imposition of this                 
          addition to tax is mandatory where prepayments of tax, either               
          through withholding or by making estimated quarterly tax payments           
          during the course of the taxable year, do not equal the                     
          percentage of total liability required under the statute.  Sec.             
          6654(a); Niedringhaus v. Commissioner, 99 T.C. 202, 222 (1992);             
          Grosshandler v. Commissioner, 75 T.C. 1, 20-21 (1980).                      
          Petitioner bears the burden of proving his entitlement to any               
          exception.  Habersham-Bey v. Commissioner, 78 T.C. 304, 319-320             
          (1982).                                                                     





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