- 9 - file and pay for each year in issue was due to reasonable cause and not due to willful neglect. Accordingly, we sustain the determinations of respondent with respect to the section 6651(a)(1) and (2) additions to tax. We further sustain respondent’s assertion of increased deficiencies under section 6651(a)(2) for the years 1996, 1997, and 1998. Lopez v. Commissioner, T.C. Memo. 2001-93. Subject to exceptions that do not apply in this case, section 6654(a) provides for an addition to tax “in the case of any underpayment of estimated tax by an individual”. Although required to do so, petitioner made no estimated tax payments during any year in issue. Therefore, respondent’s imposition of the addition to tax under section 6654(a) for each year in issue is sustained. Reviewed and adopted as the report of the Small Tax Case Division. Decision will be entered for respondent.Page: Previous 1 2 3 4 5 6 7 8 9 10
Last modified: May 25, 2011