- 34 - and extenuating circumstances are irrelevant.” Estate of Ruben v. Commissioner, 33 T.C. 1071, 1072 (1960); see also Grosshandler v. Commissioner, supra at 21. None of the statutory exceptions under section 6654(e) applies in this case. Petitioner concedes that as of the date the statutory notice of deficiency was mailed to him, he had not made any estimated tax payments for 1990, 1991, 1993, and 1994. Petitioner did not present any argument on this issue; therefore, the issue is deemed conceded. Respondent’s determination is sustained. We have carefully considered the remaining arguments of both parties for results contrary to those expressed herein, and, to the extent not discussed above, find those arguments to be irrelevant, moot, or without merit. To reflect the foregoing and the concessions of the parties, Decision will be entered under Rule 155.Page: Previous 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34
Last modified: May 25, 2011