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It is undisputed that petitioner received both unemployment
compensation and compensation as an independent contractor for
the years at issue and failed to make estimated tax payments.
Upon the basis of the record, petitioner does not qualify
for any of the exceptions listed in section 6654(e). Therefore,
we hold that he is liable for the additions to tax pursuant to
section 6654(a) for the 1988, 1989, and 1990 taxable years.
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