- 11 - 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 sectionPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011