Richard T. Wallace - Page 8

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          not more than 1 month, with an additional 5 percent for each                
          month in which the failure to file continues, to a maximum of 25            
          percent of the tax in the aggregate.  The addition to tax is                
          applicable unless it is shown that the failure to file is due to            
          reasonable cause and not due to willful neglect.                            
               There is no evidence in the record that suggests that                  
          petitioner's failure to file a Federal income tax return for any            
          year in issue was due to reasonable cause and not due to willful            
          neglect.  It was petitioner's burden to produce such evidence,              
          Rule 142(a), and this he has failed to do.  Consequently, we                
          sustain respondent's determination that petitioner is liable for            
          the additions to tax under section 6651(a)(1) for the years 1990            
          through 1993.                                                               
               4.  Section 6654 Additions to Tax                                      
               For the years 1991 through 1993 respondent determined that             
          petitioner is liable for the additions to tax under section 6654            
          for his failure to make estimated tax payments.  Section 6654               
          provides for an addition to tax if estimated taxes are underpaid.           
          It contains no provision relating to reasonable cause and lack of           
          willful neglect.  Because petitioner failed to make any estimated           
          tax payments for each of the years 1991 through 1993,                       
          respondent's determination is sustained.  Grosshandler v.                   
          Commissioner, 75 T.C. 1, 20-21 (1980).                                      
               To reflect the foregoing,                                              






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