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respondent erred in determining an addition to tax under section
6654. Accordingly, we sustain respondent's determination and
find petitioner liable under section 6654 for his failure to make
estimated tax payments for 1986 through 1988.
We have considered all other arguments made by the parties
and found them to be either irrelevant or without merit.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011