- 6 - 1996. Furthermore, petitioner’s wife was available to assist petitioner with his finances for at least a portion of the time, and petitioner also had an accountant available who helped him request the extensions of time to file. Consequently, while we are sympathetic of petitioner’s situation, we find that he did not have reasonable cause for failing to file timely his 1995 and 1996 Federal income tax returns and to pay the tax shown on the 1996 substitute return. We sustain respondent’s determination that petitioner is liable for the additions to tax under section 6651(a)(1) and (2). The correct amounts of the additions to tax must be calculated in the Rule 155 computations required in this case. We next address whether petitioner is liable for the section 6654(a) addition to tax for failure to make estimated Federal income tax payments for 1995 and 1996. Unless the taxpayer demonstrates that one of the statutory exceptions applies, imposition of the section 6654(a) addition to tax is mandatory where prepayments of tax, either through withholding or by making estimated quarterly tax payments during the course of the taxable year, do not equal the percentage of total liability required under the statute. See sec. 6654(a); Niedringhaus v. Commissioner, 99 T.C. 202, 222 (1992). Petitioner did not address this issue separately from the section 6651(a) issue. However, there is no “reasonable cause”Page: Previous 1 2 3 4 5 6 7 8 Next
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