Percy Rodgers, Jr. - Page 5




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          is due to reasonable cause and not due to willful neglect”.                 
          Petitioner has not presented any evidence establishing a                    
          reasonable cause for his failure to file a return, thus we hold             
          petitioner is liable for the section 6651(a)(1) addition to tax.            
               Section 6654(a) provides for an addition to tax “in the case           
          of any underpayment of estimated tax by an individual”.  Section            
          6654 does not provide relief for reasonable cause.  Petitioner              
          presented no argument regarding payments of estimated tax.  We              
          thus hold petitioner liable for the section 6654(a) addition to             
          tax.                                                                        
               Reviewed and adopted as the report of the Small Tax Case               
          Division.                                                                   
                                                  Decision will be entered            
                                             for respondent.                          
























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