-11- cause and not due to willful neglect. Accordingly, we sustain respondent's determination that he is liable for additions to tax under section 6651(a)(1). 3. Additions to Tax Under Section 6654 Respondent determined an addition to tax under section 6654 for each year in issue, asserting that petitioner failed to pay estimated tax. This addition to tax is mandatory unless petitioner proves that he has met one of the exceptions contained in section 6654. In re Sanford, 979 F.2d at 1514; Recklitis v. Commissioner, 91 T.C. 874, 913 (1988). Because petitioner has failed to do so, we sustain respondent on this issue. To reflect the foregoing, Decision will be entered for respondent.Page: Previous 1 2 3 4 5 6 7 8 9 10 11
Last modified: May 25, 2011