Chester J. Janas - Page 5

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                  Respondent determined that petitioner is liable, pursuant to                            
            section 6654, for failure to pay estimated income tax.  Section                               
            6654 imposes an addition to tax for failure to make estimated                                 
            income tax payments.  Petitioner has the burden, see Welch v.                                 
            Helvering, supra, but failed to prove that respondent's                                       
            determination is wrong.  Petitioner's only contention relating to                             
            this issue is a general denial of liability contained in the                                  
            petition.  Petitioner did not remit estimated payments in a                                   
            timely manner, and no tax payments were withheld from his                                     
            compensation.  Accordingly, petitioner is liable for the section                              
            6654 additions to tax.                                                                        
                  All other contentions raised by the parties are either                                  
            irrelevant or without merit.                                                                  
                  To reflect the foregoing,                                                               
                                                              Decision will be entered                    
                                                        pursuant to Rule 155.                             


















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