- 5 - return was due to reasonable cause and not willful neglect. Rule 142(a); Baldwin v. Commissioner, 84 T.C. 859, 870 (1985). Petitioner, however, did not dispute his liability for this addition to tax. As a result, petitioner has failed to carry his burden of proof and is liable for the addition to tax. III. Addition to Tax for Failure To Make Estimated Tax Payments Section 6654 imposes an addition to tax for failure to make estimated income tax payments. Petitioner bears the burden of proving that he paid estimated tax or that an exception applies. Rule 142(a); Grosshandler v. Commissioner, 75 T.C. 1, 20-21 (1980). Petitioner, however, did not dispute his liability for this addition to tax. As a result, petitioner has failed to carry his burden of proof and is liable for the addition to tax. We have considered the other arguments made by petitioner and respondent and found them to be either irrelevant or without merit. To reflect the foregoing, Decision will be entered under Rule 155.Page: Previous 1 2 3 4 5
Last modified: May 25, 2011