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