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3. Section 6655(a)
Section 6655(a) imposes an addition to tax for failure to
pay estimated income tax. Petitioners bear the burden of
disproving respondent's determination of an addition to tax
pursuant to section 6655(a). Rule 142(a).
As petitioners paid no estimated tax and offered no evidence
to explain their failure to do so, we sustain respondent's
determination. Id.
4. Section 6656(a)
Section 6656(a) imposes an addition to tax for failure to
deposit timely a tax in a Government depositary. The addition to
tax is equal to 10 percent of the underpayment.37 The addition
to tax does not apply if the failure to deposit timely is due to
reasonable cause and not to willful neglect. Sec. 6656(a).
As with the section 6651(a)(1) additions to tax, petitioners
seek to establish reasonable cause by showing their reliance on
the opinion of their tax adviser and accountants. We apply the
standard for "reasonable cause" in section 6651(a)(1) to section
6656(a). We have held that LTD is liable for corporate income
tax for taxable years ended June 30, 1987 through 1989, that LTD
is liable as a withholding agent for withholding tax on the
37
Sec. 8001(a) of the Omnibus Budget Reconciliation Act of
1986, Pub. L. 99-509, 100 Stat. 1951, sets the amount of such
addition to tax at 10 percent of the amount of the underpayment,
effective for amounts assessed after Oct. 21, 1986, the date of
the enactment of the amendment.
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