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first time in the answer. Rule 142(a). Section 6653(a) provides
that if any part of an underpayment of tax required to be shown
on a return is due to negligence or intentional disregard of
rules and regulations, there shall be added to the tax an amount
equal to 5 percent of the underpayment.
Petitioner's 1979 tax liability was $41,210, but he failed
to file a return. Therefore, petitioner had an underpayment of
$41,210. See secs. 6211, 6653(c)(1). In addition, petitioner
intentionally disregarded applicable rules and regulations
requiring the filing of a return and the reporting of income.
Accordingly, we hold that he is liable for the section 6653(a)
addition to tax.
All other arguments made by the parties are either
irrelevant or without merit.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011