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significantly different after the education from what they were
before, the expenditures are not deductible if the education
qualifies the taxpayer for a new trade or business. The record
does not support a holding that petitioner is entitled to a
deduction for educational expenses for 1997. The Court holds for
respondent on this issue.
Section 6651(a)(1) provides an addition to tax for the
failure to file a return. Section 6651(a)(2) provides an
addition to tax for the failure to pay the tax shown or required
to be shown on a return. Section 6654(a) provides an addition to
tax for the failure to pay estimated taxes.
Petitioner did not file an income tax return for 1997. He
made no payments of his estimated tax for 1997 and offered no
evidence to show that any tax was withheld on any income earned
by petitioner during 1997. At trial, petitioner admitted that,
to the extent that he would be liable for the deficiency in tax,
the additions to tax would be applicable. Petitioner presented
no evidence that would absolve him of these additions to tax.
Under the Court's holdings on the issues, petitioner will owe a
deficiency in tax and the aforesaid additions to tax will apply.
Respondent, therefore, is sustained on this issue.
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Last modified: May 25, 2011