- 9 -
has no provision relating to reasonable cause and lack of willful
neglect. It is mandatory and extenuating circumstances are
irrelevant.”) None of the statutory exceptions under section
6654(e) applies in this case.
Respondent determined that petitioner is liable for an
addition to tax under section 6654 for each tax year at issue.
He subsequently conceded, however, that petitioner is not liable
for the addition to tax under section 6654 for 1994 and 1996.
Petitioner conceded at trial that he did not make any payments of
estimated tax. Since petitioner was required to make estimated
tax payments for all of the years at issue except 1994 and 1996
and he failed to do so, respondent’s determination as modified is
sustained.
To reflect the foregoing and the concessions of the parties,
Decision will be entered
under Rule 155.
Page: Previous 1 2 3 4 5 6 7 8 9
Last modified: May 25, 2011