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petitioner fraudulently failed to file his Federal income tax
returns for 1993, 1994, and 1995.
Section 6654(a) provides for an addition to tax for failure
to make timely estimated income tax payments. Petitioner has not
proven that an exception applies, and for each year in issue,
petitioner is liable for the section 6654 addition to tax.
To reflect the foregoing,
Decisions will be entered
under Rule 155.
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Last modified: May 25, 2011