Thomas Y. Wallace - Page 14




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          for an addition to tax pursuant to section 6653(a) for taxable              
          year 1988.                                                                  
          Failure To File for 1988                                                    
               Section 6651(a)(1) imposes an addition to tax for failure to           
          file a timely return, unless the taxpayer can establish that such           
          failure “is due to reasonable cause and not due to willful                  
          neglect”.  It is undisputed that petitioner did not file a 1988             
          Federal income tax return.  Petitioner has not argued, and the              
          evidence does not establish, that there was reasonable cause for            
          his failure to file his 1988 return.  We sustain respondent’s               
          determination on this issue.                                                
          Self-Employment Taxes                                                       
               Section 1401 generally provides that a tax shall be imposed            
          on a specified percentage of the self-employment income of every            
          individual.  Petitioner failed to address respondent’s                      
          determination that he is liable for self-employment taxes.  We              
          sustain respondent’s determination on this issue.                           
          Failure To Pay Estimated Taxes                                              
               Respondent determined an addition to tax under section 6654            
          for taxable years 1988 and 1989 based on petitioner’s failure to            
          pay estimated income tax.  Section 6654(a) provides for an                  
          addition to tax “in the case of any underpayment of estimated tax           
          by an individual”.  An addition to tax under section 6654 is                
          mandatory absent the application of one of the exceptions                   







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