Michael S. Palmer - Page 11

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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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