Jimmie E. Cannon - Page 14




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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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