Katrina L. Price - Page 15




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          that he or she meets one of the exceptions provided in section              
          6654(e), none of which apply here.  Petitioner offered no                   
          evidence to show why she did not pay estimated tax.  We conclude            
          that petitioner is liable for the addition to tax for failure to            
          pay estimated tax under section 6654 for 1993.                              
          E.   Whether Petitioner Is Liable for the Accuracy-Related                  
               Penalty for 1994                                                       
               Respondent contends that petitioner is liable for the                  
          accuracy-related penalty for negligence under section 6662(a) for           
          1994.  Taxpayers are liable for a penalty equal to 20 percent of            
          the part of the underpayment attributable to negligence or                  
          disregard of rules or regulations.  Sec. 6662(a) and (b)(1).                
          Negligence includes failure to make a reasonable attempt to                 
          comply with internal revenue laws or to exercise ordinary and               
          reasonable care in preparing a tax return.  Sec. 6662(c).                   
          Petitioner bears the burden of proving that she is not liable for           
          the accuracy-related penalty.  Rule 142(a); Tweeddale v.                    
          Commissioner, 92 T.C. 501, 505 (1989).                                      
               Petitioner made no argument and offered no evidence that she           
          is not liable for the accuracy-related penalty.  We conclude that           
          petitioner is liable for the accuracy-related penalty for 1994.             
               To reflect the foregoing,                                              
                                                       Decision will be               
                                             entered for respondent.                  







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