- 15 - required to be deposited if the failure to deposit is more than 15 days late. A taxpayer may avoid the addition to tax by showing that the failure to deposit was due to reasonable cause and not due to willful neglect. Sec. 6656(a); Charlotte’s Office Boutique v. Commissioner, supra at ___ (slip op. at 31). Petitioner asserts that he “refused to use” an employer identification number and acknowledges the obligations of an employer that he deliberately tried to avoid. Petitioner’s position is essentially that he did not want to incur the obligations of an employer and therefore did not comply with the applicable law. Petitioner is liable for the additions to tax under section 6651 and section 6656. We have considered all arguments made by the parties. Those arguments not discussed are irrelevant or without merit. To reflect the foregoing, Decision will be entered for respondent.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15
Last modified: May 25, 2011