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Commissioner, 91 T.C. 874, 913 (1988); Grosshandler v.
Commissioner, 75 T.C. 1, 20-21 (1980). Petitioner bears the burden
of proving qualification for the exceptions. See Habersham-Bey v.
Commissioner, 78 T.C. 304, 319-320 (1982).
Because petitioner did not make any estimated tax payments for
the years in issue, introduced no evidence thereon, and has not
shown that any of the exceptions apply, we sustain respondent's
determination pursuant to section 6654(a) for the years in issue.
We have considered all of petitioner's arguments and, to the
extent not discussed above, find them to be without merit.
To reflect concessions of the parties,
Decisions will be entered
under Rule 155.
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Last modified: May 25, 2011