Charol L. Stafford - Page 12

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               Section 6654(a)                                                        
               The section 6654 addition to tax for failure to pay                    
          estimated tax is mandatory unless the taxpayer establishes that a           
          statutory exception applies.  Grosshandler v. Commissioner, 75              
          T.C. 1, 20-21 (1980).  Mr. Stafford is deemed to have stipulated            
          that additions to tax under section 6654(a) for 1989 and 1990 are           
          due from him because he underpaid his estimated tax for both                
          years.  Accordingly, there is no genuine issue of material fact             
          as to this issue, and respondent's motion for summary judgment              
          thereon with respect to Mr. Stafford will be granted.                       
               Section 6662(a)                                                        
               Section 6662(a) imposes a 20-percent penalty on the portion            
          of an underpayment attributable to, inter alia, negligence or               
          disregard of rules or regulations.5  Mrs. Stafford is deemed to             
          have stipulated that the section 6662(a) penalties are due from             
          her for the underpayment of tax for 1989 and 1990.  Accordingly,            
          there is no genuine issue of material fact regarding Mrs.                   
          Stafford's liability for these penalties, and respondent's motion           
          for summary judgment thereon will be granted.                               
          3.  The Section 6673 Penalty                                                
               Petitioners are advised of the provisions of section 6673              
          giving this Court authority to impose a penalty of up to $25,000            

               5  Respondent determined in the notice of deficiency with              
          respect to Mrs. Stafford that all or part of the underpayment for           
          1990 and 1991 is due to negligence or intentional disregard of              
          rules or regulations.                                                       




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