-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