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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.
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Last modified: May 25, 2011