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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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