- 4 - (1982). Nothing in the record suggests that petitioner applied for an extension of time to file his 1994 return. Petitioner did not show that as of the due date of his 1994 return he did not have information showing the amount of his income for 1994. Nor did he establish that he could not have prepared a timely 1994 return with a reasonable degree of accuracy based on the informa- tion available to him as of the due date of that return. On the record before us, we find that petitioner has not demonstrated that the failure to file timely his 1994 return was due to reasonable cause, and not to willful neglect. We further find on that record that petitioner is liable for 1994 for the addition to tax under section 6651(a)(1). Section 6654(a) imposes an addition to tax in the case of any underpayment of estimated tax by an individual. The addition to tax under section 6654(a) is mandatory unless petitioner qualifies under one of the exceptions in section 6654(e). See Grosshandler v. Commissioner, 75 T.C. 1, 20-21 (1980). Peti- tioner claims that he made estimated tax payments with respect to the income that he expected to earn for 1994 and that one of the reasons why he did not make the appropriate amount of estimated tax payments for that year related to certain unresolved tax issues for 1993 that were pending before the Internal Revenue Service. Petitioner does not argue, and did not prove, that he qualifies under any of the exceptions listed in section 6654(e).Page: Previous 1 2 3 4 5 Next
Last modified: May 25, 2011