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Respondent also determined additions to tax for late filing,
sec. 6651(a), and for failure to pay estimated tax, sec. 6654.
The section 6651 addition applies unless the taxpayer shows that
the failure to file was due to reasonable cause and not willful
neglect. Petitioner admits that he did not file a 1994 return,
and we have rejected his reasons for not doing so. Accordingly,
we hold that petitioner is liable for the section 6651(a)
addition to tax as determined by respondent. The section 6654
addition applies in a mathematical fashion unless it is shown
that any of certain statutory exceptions apply. See Grosshandler
v. Commissioner, 75 T.C. 1, 20-21 (1980). Petitioner has not
shown that any such exceptions apply, and, accordingly, we hold
that respondent’s section 6654 determination is sustained.
To reflect the foregoing,
Decision will be entered for
respondent.
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Last modified: May 25, 2011