Henry F. K. Kersting - Page 20




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          Commissioner, supra.  We sustain respondent's determination of              
          additions to tax for negligence for all of the years in issue.              
               Respondent determined an addition to tax against petitioner            
          under section 6654(a) for failure to make timely estimated tax              
          payments.  This addition to tax generally is mandatory and cannot           
          be waived due to reasonable cause.  See Recklitis v.                        
          Commissioner, 91 T.C. 874, 913 (1988); Grosshandler v.                      
          Commissioner, 75 T.C. 1, 21 (1980);  Estate of Ruben v.                     
          Commissioner, 33 T.C. 1071, 1072 (1960); sec. 1.6654-1(a), Income           
          Tax Regs.  However, no addition to tax is imposed under section             
          6654(a) if one of the exceptions set forth in section 6654(e) is            
          satisfied.  Petitioner presented no evidence that an exception              
          applies and failed to address this issue on brief.  We sustain              
          respondent's determination of the addition to tax under section             
          6654 for all years in issue.                                                
               We have considered all arguments made by petitioner, and, to           
          the extent not addressed above, find them to be without merit.              
          To reflect the foregoing,                                                   

                                                  An appropriate order                
                                             will be issued and decision              
                                             will be entered for respondent           









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