- 7 - that the taxpayer bears the burden of proof regarding reasonable cause). Accordingly, on this issue, we sustain respondent’s determination. 2. Section 6651(a)(2). Failure To Pay Section 6651(a)(2) provides for an addition to tax where payment of tax is not timely “unless it is shown that such failure is due to reasonable cause and not due to willful neglect”. Under penalty of perjury, Revenue Agent Laakso swore that respondent’s records reflect that petitioner failed to pay income taxes for the years in issue. Based upon the evidence, we find as a fact that petitioner did not pay his taxes for the years in issue. Petitioner did not present evidence indicating that his failure to pay was due to reasonable cause and not due to willful neglect. See Higbee v. Commissioner, supra at 446-447 (stating that the taxpayer bears the burden of proof regarding reasonable cause). Accordingly, on this issue, we sustain respondent’s determination. 3. Section 6654. Failure To Pay Estimated Tax Section 6654 imposes an addition to tax for failure to pay estimated income tax. Respondent submitted petitioner’s Forms W-2 and petitioner’s transcript of account listing Forms 1099B, 1099S, 1099DIV, and 1099INT received by the IRS for 1996 and 1997. The forms indicate that no Federal income tax was withheld. On the basis of this evidence and the declaration ofPage: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011