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without published opinion 559 F.2d 1207 (3d Cir. 1977); see also
Commissioner v. Lane-Wells Co., 321 U.S. 219 (1944). Petitioner
filed an incomplete Form 1040NR on which he reported no income or
other amounts. Petitioner offered no evidence to show, contrary
to respondent's determination, that his Form 1040NR is a valid
return for purposes of section 6651(a)(1). Petitioner's Form
1040NR is not a valid return for purposes of section 6651.
Petitioner made no attempt to show that his failure to file
a timely return was due to reasonable cause and not willful
neglect except for his frivolous contentions about the income tax
system. We sustain respondent's determination that petitioner is
liable for the addition to tax for failure to file a return under
section 6651(a) for 1992.
E. Failure To Pay Estimated Tax
Respondent also 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 applies unless the taxpayer shows that he or she
meets one of the computational exceptions provided in section
6654(e), none of which applies here. Petitioner offered no
evidence to show why he did not pay estimated tax. 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.
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