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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.
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Last modified: May 25, 2011