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income tax returns for the years in issue and is liable for the
addition to tax pursuant to section 6651(a)(1).
We next address the issue of the addition to tax for failure
to pay estimated income tax under section 6654(a) for the years
in issue. This Court stated in Estate of Ruben v. Commissioner,
33 T.C. 1071, 1072 (1960): "This section has no provision
relating to reasonable cause and lack of willful neglect. It is
mandatory and extenuating circumstances are irrelevant."
Petitioner has failed to show that he did not underpay his
estimated tax for the years in issue. Accordingly respondent's
determination is sustained.
Having fully reviewed the record in this case, we hold that
respondent's determinations as set forth in the notice of
deficiency must be sustained, except for the concessions by
respondent, as previously noted.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011