- 8 - exemption for a dependent child. Accordingly, we conclude that petitioner is entitled to an additional exemption for each year at issue. Finally, respondent determined that petitioner is liable for the addition to tax for failure to file a timely return under section 6651(a)(1) and the addition to tax for failure to pay estimated income tax under section 6654(a). Petitioner has not put forth any evidence to indicate that his failure to file tax returns was due to reasonable cause and not due to willful neglect. Sec. 6651(a); United States v. Boyle, 469 U.S. 241 (1985). Further, petitioner has not shown that he satisfied any of the exceptions under section 6654. Accordingly, we sustain respondent's determinations on these issues. To reflect the foregoing, Decision will be entered under Rule 155.Page: Previous 1 2 3 4 5 6 7 8
Last modified: May 25, 2011