- 5 - return for 1996 and offered no evidence showing that his failure to file was due to reasonable cause and not due to willful neglect. Accordingly, we hold that petitioner is liable for the addition to tax under section 6651(a)(1). B. Section 6651(a)(2): Failure To Pay Respondent also determined that petitioner is liable for an addition to tax pursuant to section 6651(a)(2) for 1996. Petitioner presented no evidence or argument that the addition was improper. Additionally, petitioner did not present evidence indicating that his failure to pay was due to reasonable cause and not due to willful neglect. Accordingly, on this issue, we sustain respondent’s determination. C. Section 6654(a): Failure To Pay Estimated Tax Respondent determined that petitioner is liable for an addition to tax pursuant to section 6654(a) for 1996. Section 6654(a) imposes an addition to tax for failure to pay estimated income tax. Petitioner did not offer any evidence at trial related to this issue and failed to address it on brief. Therefore, we sustain respondent’s determination on this issue. III. Section 6673(a)(1) Penalty Section 6673(a)(1) authorizes this Court to require a taxpayer to pay to the United States a penalty not to exceed $25,000 if the taxpayer took frivolous positions in the proceedings or instituted the proceedings primarily for delay. APage: Previous 1 2 3 4 5 6 Next
Last modified: May 25, 2011