- 4 - 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.Page: Previous 1 2 3 4 5
Last modified: May 25, 2011