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unpersuaded by this claim. It is clear that the Federal income tax
reaches income that is earned in the United States by an alien even
if deemed a nonresident. See secs. 61, 872, 7701(b); see also
secs. 861(a)(1) and (3), 864(b).
Respondent also determined an addition to tax under section
6654 for each year in issue, asserting that petitioner failed to
pay estimated tax. This addition to tax is mandatory unless
petitioner proves he met one of the exceptions contained in section
6654. Recklitis v. Commissioner, 91 T.C. 874, 913 (1988).
Petitioner has failed to do so. Accordingly, we sustain
respondent's determinations under section 6654.
To reflect the foregoing,
Decision will be entered for
respondent.
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Last modified: May 25, 2011