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percentage of total liability required under the statute,
imposition of the addition to tax under section 6654(a) is
automatic, unless petitioners show that one of the statutory
exceptions applies. See Niedringhaus v. Commissioner, 99 T.C.
202, 222 (1992); Habersham-Bey v. Commissioner, 78 T.C. 304, 319-
320 (1982); Grosshandler v. Commissioner, 75 T.C. 1, 20-21
(1980). Petitioners have provided no evidence that any of these
exceptions apply. Therefore, we sustain respondent on this
issue. The correct amounts of underpayment and additions to tax
under sections 6651(a) and 6654 will be determined under Rule
155.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011