- 16 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
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