- 11 - argument is without merit. For 1995, petitioners argue that they were unable to file a return because they were notified that they were under audit and were in the midst of the appeal process. We do not believe that these circumstances demonstrate reasonable cause for failure to file a return. We conclude that petitioners are liable for the additions to tax pursuant to section 6651(a)(1) for 1994 and 1995. Failure To Pay Estimated Income Tax Respondent determined that petitioners were liable for an addition to tax for their failure to pay estimated Federal income tax under section 6654(a) in 1995. This addition to tax is mandatory in the absence of a showing by petitioners that a statutory exception applies. See Grosshandler v. Commissioner, 75 T.C. 1, 20-21 (1980). Petitioners failed to present any evidence demonstrating that a statutory exception applies in this case. Accordingly, we sustain respondent's determination. To reflect the foregoing, Decision will be entered under Rule 155.Page: Previous 1 2 3 4 5 6 7 8 9 10 11
Last modified: May 25, 2011