David Russell Jacobson - Page 6

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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