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deductions”), affg. and vacating on another issue 80 T.C. 34
(1983); Malinowski v. Commissioner, 71 T.C. 1120, 1124-1125
(1979); Sentinel Fin. Servs. v. Commissioner, T.C. Memo. 1992-
733, affd. without published opinion 39 F.3d 1188 (9th Cir.
1994).
Section 6651(a)(1) provides for an addition to tax for
failure to file Federal income tax returns. As discussed above,
we do not believe petitioner’s belated claim that he filed timely
returns. He has shown no reasonable cause for failure to file
the returns, and the section 6651(a)(1) addition to tax is
sustained.
The addition to tax for failure to make estimated tax
payments under section 6654 is imposed in the absence of special
exceptions not applicable here. See generally Grosshandler v.
Commissioner, 75 T.C. 1, 20-21 (1980).
To reflect respondent’s concessions,
Decision will be entered
under Rule 155.
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