- 15 -
petitioner is liable for additions to tax under section
6651(a)(1).
Section 6654(a) requires the imposition of an addition to
tax in the case of any underpayment of estimated tax by an
individual. See Estate of Ruben v. Commissioner, 33 T.C. 1071,
1072 (1960). Section 6654(e) provides exceptions to the
imposition of additions to tax under section 6654(a). Petitioner
bears the burden of proving that one of these exceptions is
applicable. Petitioner introduced no evidence as to the
applicability of the exceptions provided under section 6654(e).
Accordingly, petitioner is liable for the addition to tax under
section 6654(a).
To reflect the foregoing,
Decision will be entered under
Rule 155.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15
Last modified: May 25, 2011