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section 6662(a) accuracy-related penalty with regard to his
entire underpayment for each year in issue.
Mrs. Beck’s Liability for Section 6654(a) Additions to Tax
Respondent determined that for each year in issue, Mrs. Beck
is liable for the section 6654(a) addition to tax for
underpayment of estimated tax by an individual. During the years
in issue, Mrs. Beck filed no returns and paid no estimated taxes.
Mrs. Beck has not shown that any of the exceptions contained
in section 6654(e) apply. Therefore, we hold that she is liable
for the section 6654(a) addition to tax for each year in issue.
To reflect the foregoing and concessions by respondent,
Decisions will be entered
under Rule 155.
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