- 7 - Petitioner did not file Federal income tax returns or applications for extensions of time to file for 1990, 1994, or 1996. Petitioner stated in his petition that he was not liable for penalties as determined by respondent. The record is devoid of any evidence establishing a reasonable cause for his failure to file a return; thus, we hold petitioner is liable for the section 6651(a)(1) addition to tax. IV. Section 6654(a) Addition to Tax Section 6654(a) imposes an addition to tax in the case of any underpayment of estimated tax by an individual. Unless a statutory exception applies, the addition to tax under section 6654(a) is mandatory. See sec. 6654(a), (e); Recklitis v. Commissioner, 91 T.C. 874, 913 (1988); Grosshandler v. Commissioner, 75 T.C. 1, 20-21 (1980); Estate of Ruben v. Commissioner, 33 T.C. 1071, 1072 (1960) (“This section has no provision relating to reasonable cause and lack of willful neglect. It is mandatory and extenuating circumstances are irrelevant.”). None of the statutory exceptions under section 6654(e) applies in this case. Petitioner stated in his petition that he was not liable for penalties as determined by respondent, but presented no further argument regarding payments of estimated tax. We thus hold petitioner liable for the section 6654(a) addition to tax.Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011