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Commissioner, 92 T.C. 342, 350 (1989), affd. 898 F.2d 50 (5th
Cir. 1990). Accordingly, we sustain respondent's determination.
Section 6654(a)
Section 6654 imposes an addition to tax for failure to pay
estimated tax. This addition to tax is mandatory unless a
taxpayer is able to qualify under the specific exceptions set
forth in section 6654(d). Grosshandler v. Commissioner, 75 T.C.
1, 20-21 (1980). Reasonable cause and lack of willful neglect
are not defenses to this addition to tax. Petitioner had no
income taxes withheld from his wages and made no estimated tax
payments during 1983. Moreover, petitioner presented no evidence
that he falls within any of the enumerated exceptions under
section 6654(d). Accordingly, we sustain respondent's
determination.
Section 6661(a)
Section 6661(a) provides a 10-percent addition to tax if
there is a substantial understatement of income tax. An
understatement is "substantial" if it exceeds the greater of 10
percent of the tax required to be shown for the taxable year or
$5,000. In view of respondent's concession that petitioner is
taxable on one-half of the income, the amount of the deficiency
herein will not exceed $5,000. Accordingly, we do not sustain
respondent's determination on this issue.
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