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Petitioner received taxable income during each of the years
in issue and did not make any estimated tax payments. Petitioner
has not proven that any of the exceptions to section 6654(a)
apply. Thus, petitioner is liable for the section 6654(a)
additions to tax for the years in issue.
To reflect the foregoing,
Decision will be entered
for respondent except as to the
additions to tax under section
6651(f).
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Last modified: May 25, 2011