- 14 - 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 exceptionsPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011