- 13 - was instructed by his income tax return preparer not to file any Federal income tax returns during respondent’s criminal investigation of petitioners’ 1982 and 1983 returns. Petitioner, however, has offered no explanation for not filing his 1984 income tax return immediately after the conclusion in 1990 of the criminal tax proceedings against him. We sustain respondent’s determination of this addition to tax. Finally, we sustain for 1984 respondent’s determination under section 6654 of the addition to tax for the failure of petitioner to pay estimated taxes. Petitioner did underpay estimated taxes with regard to income earned in 1984, and petitioner does not meet any of the exceptions to the requirement to pay estimated taxes. Sec. 6654(d). To reflect the foregoing, Decisions will be entered under Rule 155.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13
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