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