- 10 - section 6654(a) is mandatory unless petitioner can prove that she complies with one of the exceptions contained in section 6654(e). Baldwin v. Commissioner, 84 T.C. 859, 871 (1985); Grosshandler v. Commissioner, 75 T.C. 1, 20-21 (1980). Petitioner is deemed to have admitted "liability for the additions [sic] to tax under I.R.C. sec. 6654 as determined in the notice of deficiency." Accordingly, we sustain respondent's determination as to the addition to tax under section 6654. The amount of the addition is $1,553, the amount set forth in respondent's recomputation. To reflect the foregoing, An order granting respondent's oral motion for summary judgment and decision will be entered for respondent.Page: Previous 1 2 3 4 5 6 7 8 9 10
Last modified: May 25, 2011