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mated tax payments was somehow related to Form W-4, Employee’s
Withholding Allowance Certificate (Form W-4), which was filed
with an office of the government of the State of Kentucky.
Petitioner has not made any argument that any of the exceptions
in section 6654(e) apply in the instant case. On the record
before us, we find that petitioner has not met his burden of
proving that he is not liable for the year at issue for the
addition to tax under section 6654(a).
To reflect the foregoing and the concessions of the parties,
Decision will be entered under
Rule 155.
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Last modified: May 25, 2011