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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.
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Last modified: May 25, 2011