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total amounts of credits for withholding and estimated tax
payments:
Total Amount of
Year Credits Claimed
1992 $60,798.52
1993 74,603.50
1994 76,693.55
1995 43,755.09
1996 15,524.82
On the record before us, we reject petitioners’ contention. We
find on that record that petitioners have failed to carry their
burden of showing that they are entitled for each of the years at
issue to a total amount of credits for withholding and estimated
tax payments in excess of the total amount of such credits
determined by respondent for each such year.
Additions to Tax Under Sections 6651(a) and 6654
Petitioners presented no evidence, and advance no argument,
with respect to the additions to tax under sections 6651(a) and
6654 that respondent determined. On the record before us, we
find that petitioners have failed to show that they are not
liable for each of the years at issue for the additions to tax
under sections 6651(a)(1) and 6654. On that record, we further
find that petitioners have failed to show that they are not
liable for 1996 for the addition to tax under section
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Last modified: May 25, 2011