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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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Last modified: May 25, 2011