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F. Failure To Pay Estimated Tax
Respondent determined that petitioner is liable for the
addition to tax for failure to pay estimated tax under section
6654.
The addition to tax for failure to pay estimated tax under
section 6654 is mandatory unless the taxpayer can show that he
meets one of the computational exceptions provided in section
6654(e), none of which apply here. Baldwin v. Commissioner,
supra at 871; Grosshandler v. Commissioner, 75 T.C. 1, 20-21
(1980). Petitioner offered no evidence about why he did not pay
estimated tax other than his protester arguments. We sustain
respondent's determination that petitioner is liable for the
addition to tax for failure to pay estimated tax under section
6654 for 1992 and 1993.
To reflect the foregoing,
Decision will be
entered for respondent.
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Last modified: May 25, 2011