- 22 -
1514; Recklitis v. Commissioner, 91 T.C. 874, 913 (1988).
Petitioner has failed to show that any of the statutory
exceptions apply. Accordingly, we sustain respondent's
determination under section 6654 for petitioner's 1985 taxable
year.
We have considered all arguments made by petitioner for a
contrary holding and, to the extent not discussed above, find
them to be without merit.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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