Bradley G. Bjelk - Page 23

                                       - 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