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Respondent also determined that petitioner is liable for
additions to tax pursuant to section 6654(a) for failure to pay
estimated income tax. For the years in issue, petitioner had
substantial taxable income but made no estimated tax payments.
Imposition of the addition to tax under section 6654(a) applies
unless petitioner shows that one of the several statutory
exemptions applies. Sec. 6654(a); Niedringhaus v. Commissioner,
supra at 222; Grosshandler v. Commissioner, 75 T.C. 1, 20-21
(1980). Petitioner has made no such showing.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011