- 12 - reasonable cause under section 6651(a). Manning v. Commissioner, 614 F.2d 815, 817 (1st Cir. 1980), affg. T.C. Memo. 1979-146; see Heman v. Commissioner, 283 F.2d 227, 232 (8th Cir. 1960), affg. 32 T.C. 479 (1959) (erroneous belief that no tax is due is not reasonable cause for failure to file fiduciary return). There is no evidence that petitioner tried to calculate his taxable income for 1990. Petitioner has not shown that he had reasonable cause under section 6651(a). We conclude that petitioner is liable for the addition to tax for failure to file his 1990 return under section 6651(a). D. Whether Petitioner is Liable for the Addition to Tax for Failure to Pay Estimated Tax Under Section 6654 The addition to tax for failure to pay estimated tax under section 6654 is mandatory unless the taxpayer shows that he meets one of the exceptions in section 6654(d), none of which apply here. Baldwin v. Commissioner, supra at 871; Grosshandler v. Commissioner, 75 T.C. 1, 20-21 (1980). Extenuating circumstances and reasonable cause are not relevant under section 6654. Baldwin v. Commissioner, supra; Bagur v. Commissioner, 66 T.C. 817, 824 (1976), remanded on other issues 603 F.2d 491 (5th Cir. 1979). Petitioner did not argue this issue on brief. We conclude that he is liable for the addition to tax for 1990 for failure to pay estimated tax. To reflect concessions and the foregoing, Decision will be entered under Rule 155.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12
Last modified: May 25, 2011