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Additions to Tax
Year Deficiency Sec. 6651(a)1 Sec. 6654(a)
1994 $20,835 $3,084 $303
1995 7,778 195 424
The only issues remaining for decision are whether peti-
tioner is liable for 1994 for the additions to tax under sections
6651(a) and 6654(a). We hold that he is.
Some of the facts have been stipulated and are so found.
Petitioner resided in Indialantic, Florida, at the time the
petition was filed.
At all relevant times, petitioner worked as a catastrophe
insurance claims adjuster. His income from that work depended,
inter alia, upon whether there was bad weather. Given the nature
of petitioner's work, it was difficult for him to determine the
amount of income that he would earn from year to year.
Petitioner filed his 1994 tax return on or about October 3,
1997. Petitioner contends that the reason that he filed his 1994
return late was because he wanted to make sure that he completed
that return accurately, and he was concerned that if he filed an
inaccurate return, he would be penalized.
Petitioner claims that he made estimated tax payments with
respect to the income that he expected to earn for 1994. He
1 All section references are to the Internal Revenue Code
in effect for the years at issue. All Rule references are to the
Tax Court Rules of Practice and Procedure.
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Last modified: May 25, 2011