- 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