Edward T. O'Toole - Page 13





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          petitioner did not show that he deposited funds in addition to              
          the taxes withheld from him in those years, that respondent’s               
          determinations with respect to the section 6654 addition were               
          erroneous, or that any exception applies in the years in issue.             
               We conclude that petitioner is liable for the addition to              
          tax for failure to pay estimated tax under section 6654 for the             
          years in issue.                                                             
                                                       Decision will be               
                                                  entered under Rule 155.             































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Last modified: May 25, 2011