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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.
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