Estate of Haines B. Gaffner - Page 11




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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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