Kevin James Cullinane - Page 4




                                        - 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