Marian and Maria Juskuv - Page 10




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          4.  Addition to Tax for Failure To Pay Estimated Income Taxes               
               Section 6654(a) imposes an addition to tax where prepayments           
          of tax, either through withholding or estimated quarterly tax               
          payments during the year, do not equal the percentage of total              
          liability required under the statute.  However, the addition to             
          tax is not imposed if the taxpayer can show that one of several             
          exceptions applies.  See sec. 6654(e).                                      
               On the basis of the record, petitioners do not qualify for             
          any of the exceptions listed in section 6654(e).  Therefore, we             
          hold that they are liable for the addition to tax pursuant to               
          section 6654(a) for 1995.  Respondent is sustained on this issue.           
               To reflect the foregoing,                                              
                                                  Decision will be entered            
                                             under Rule 155.                          























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