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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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