Edward T. O'Toole - Page 12

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          and O. Toole.  Petitioner contends that his failure to report               
          those amounts in income was due to reasonable cause.  We                    
               It should have been obvious to petitioner that the amounts             
          were taxable to him because his Social Security number appears on           
          the Forms 1099, 1098, and W-2.  Petitioner has not shown that his           
          failure to file was due to reasonable cause and not willful                 
          D.   Whether Petitioner Is Liable for the Addition to Tax for               
               Failure To Pay Estimated Tax                                           
               Respondent determined that petitioner is liable for the                
          addition to tax under section 6654 for failure to pay estimated             
          tax for the years in issue.  We have jurisdiction to review this            
          determination because petitioner did not file a return for any of           
          the years in issue.  Sec. 6665(b)(2); Meyer v. Commissioner, 97             
          T.C. 555, 562 (1991).  A taxpayer is liable for the addition to             
          tax for failure to pay estimated tax unless the taxpayer shows              
          that he or she meets one of the exceptions provided in section              
          6654(e), none of which apply here.                                          
               Petitioner contends that he had deposited enough money to              
          pay any tax liability he may have for 1993, 1994, 1995, 1996, and           
          1997.  He contends that he maintained a $5,000 “‘estimated tax              
          applied’ fund” with respondent and that the dividends he received           
          were subject to “31% backup tax” withholding.  However,                     

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