John Boyd Tenney - Page 23

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               For each year, we conclude that the increases to                       
          petitioner's taxable income that we have sustained herein                   
          relating to the specific items of income and to the bank deposits           
          are attributable to fraud.                                                  
               Section 6654(a) provides for an addition to tax for failure            
          to make timely estimated income tax payments.  Petitioner has not           
          proven that an exception applies, and for each year in issue                
          petitioner is liable for the section 6654 addition to tax.                  
               To reflect the foregoing,                                              

                                                  Decision will be entered            
                                             under Rule 155.                          



























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