- 23 - Additions to Tax The addition to tax under section 6651(a) applies in the case of failure to file a tax return, unless the failure is due to reasonable cause. Petitioner failed to file returns for all the years in issue and has offered no evidence of reasonable cause. Thus, he is liable for the additions to tax under section 6651(a). The additions to tax are based on the amount required to be shown as tax on each return, which amount will be computed under Rule 155. The additions to tax under section 6654(a) apply in the case of an underpayment of estimated tax. Petitioner failed to pay estimated tax during all the years in issue, and he has offered no evidence to show that he qualifies for one of the exceptions provided in section 6654(e). Thus, he is liable for the additions to tax under section 6654(a). The additions to tax are based on the amount of each underpayment, which amount will be computed under Rule 155. To reflect the foregoing, Decision will be entered under Rule 155.Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23
Last modified: May 25, 2011