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fact or law, and (2) that he did not seek the advice of competent
tax professionals fully informed as to the facts of petitioner's
situation. Therefore, the additions to tax under section 6651(a)
must be sustained. The additions to tax under section 6654 are
mandatory absent exceptions not applicable here. Grosshandler v.
Commissioner, 75 T.C. 1, 20-21 (1980).
We hold that petitioner is liable for the additions to tax
under sections 6651(a)(1) and 6654 for each of the years 1989
through 1993.
In order to take account of the foregoing,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011