Arthur C. Brincat - Page 15




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          circumstances, reasonable, and he is liable for the section                  
          6651(a)(1) addition to tax for 1989.                                         
               Section 6654 provides for an addition to tax in the case of             
          any underpayment of estimated tax, and this addition has been                
          held to apply unless a taxpayer shows that there is some                     
          exception to application of the addition.  See Grosshandler v.               
          Commissioner, 75 T.C. 1, 20-21 (1980).  Arthur has not shown that            
          any of the so-called safe harbors apply to his case.  See Swonder            
          v. Commissioner, T.C. Memo. 1994-430.  Accordingly, Arthur is                
          liable for the section 6654(a) addition to tax for 1989.                     
               To reflect the foregoing,                                               
                                        Decision will be entered for                   
                                   respondent in docket No. 14637-97, and              
                                   for petitioner as to the penalty and                
                                   respondent as to the deficiency in                  
                                   docket No. 18178-98.                                




















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