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Petitioner bears the burden of showing that respondent's
determination that section 6654 applies to the years in issue was
made in error. Niedringhaus v. Commissioner, supra. Petitioner
has made no such showing. For the years in issue, petitioner had
substantial taxable income; yet he made no tax payments.
Therefore, we hold he is liable for the additions to tax under
section 6654(a) for those years.
To reflect the foregoing,
Decision will be entered for
respondent.
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