Ross William Bruner - Page 7

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          in issue is due to negligence or intentional disregard of rules             
          or regulations.  Rule 142(a); Luman v. Commissioner, 79 T.C. 846,           
          860-861 (1982).                                                             
               Based on the record, we find that petitioner's entire                  
          underpayments for 1987 and 1988 are due to negligence and his               
          intentional disregard of the rules or regulations which require             
          him to report his income.  Accordingly, we hold that petitioner             
          is liable for the section 6653(a)(1)(A) and (B) additions to tax            
          for 1987 and the section 6653(a)(1) addition to tax for 1988.               
               The fourth issue for decision is whether petitioner is                 
          liable for the section 6654(a) additions to tax for failure to              
          make estimated income tax payments for 1987 and 1988.                       
               Unless the taxpayer demonstrates that one of the statutory             
          exceptions applies, imposition of the section 6654(a) addition to           
          tax is mandatory where prepayments of tax, either through                   
          withholding or by making estimated quarterly tax payments during            
          the course of the taxable year, do not equal the percentage of              
          total liability required under the statute.  Sec. 6654(a);                  
          Niedringhaus v. Commissioner, 99 T.C. 202, 222 (1992).                      
          Petitioner bears the burden of proving his entitlement to any               
          exception.  Habersham-Bey v. Commissioner, 78 T.C. 304, 319-320             
          (1982).                                                                     
               The reporting payers withheld taxes from petitioner's income           
          sources in the amounts of $189 and $659 for 1987 and 1988,                  
          respectively.  Petitioner did not make any estimated tax payments           




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