- 14 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14
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