Chris E. Columbus - Page 16

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             ordinary business care and prudence.  If petitioner was                  
             uncertain about the status of his oldest daughter as a                   
             dependent, he could have attached a statement to each                    
             return disclosing his uncertainty.  We find that petitioner              
             has not established reasonable cause for his failure to                  
             file his 1992, 1993, and 1994 income tax returns.                        
             Accordingly, we sustain respondent's determination of the                
             addition to tax under section 6651(a)(1).                                
                  Respondent determined an addition to tax for failure                
             to pay estimated income tax under section 6654 for 1992,                 
             1993, and 1994.  Section 6654(a) provides for an addition                
             to tax "in the case of any underpayment of estimated tax by              
             an individual" unless one of the exceptions contained in                 
             that section is applicable.  See generally Niedringhaus                  
             v. Commissioner, 99 T.C. 202, 222 (1992).  Petitioner's                  
             position amounts to a naked assertion that he is not liable              
             for the addition to tax under section 6654.  He has                      
             presented no evidence that any of the exceptions set forth               
             therein applies, nor has he presented any other basis to                 
             find that respondent's determination is wrong.  Accord-                  
             ingly, we sustain respondent's determination and find                    
             petitioner liable under section 6654 for his failure to                  
             make estimated tax payments for 1992, 1993, and 1994.                    







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