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April 15, 1990, and April 15, 1991, respectively. Therefore, we
find that petitioner has failed to show reasonable cause and is
liable for the addition to tax under section 6651(a)(1) for each
of the years in issue.
As to the addition to tax for failure to pay estimated tax
pursuant to section 6654(a), no relief is available unless
petitioner shows that he falls within an exception provided under
section 6654(e). Petitioner has failed to make such a showing
and therefore is liable for the addition to tax under section
6654(a) for each of the years in issue.
To reflect the foregoing,
Decision will be entered
for respondent.
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Last modified: May 25, 2011