- 12 - and O. Toole. Petitioner contends that his failure to report those amounts in income was due to reasonable cause. We disagree. 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 neglect. 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,Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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