- 4 -
Additions to Tax
Under section 6651(a)(1), an addition to tax is imposed for
failure to file a Federal income tax return. This addition to
tax will not be imposed if it is shown that the failure to file
was due to reasonable cause and not due to willful neglect.
Petitioner has not presented any evidence that his failure
to file was due to reasonable cause. Petitioner's argument that
he is not required to pay tax on compensation for services does
not constitute reasonable cause. We conclude that petitioner is
liable for the addition to tax under section 6651(a)(1).
Under section 6654(a), an addition to tax is imposed for
failure to make estimated income tax payments. Petitioner
stipulated that he made no payments of estimated tax, and
petitioner does not assert that an exception applies. We
conclude that petitioner is liable for the addition to tax under
section 6654.
To reflect the foregoing,
Decision will be entered
for respondent.
Page: Previous 1 2 3 4
Last modified: May 25, 2011