William S. Cook - Page 4




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          (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).            






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