Suzanne F. Mottola - Page 10

                                       - 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