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Williams v. Commissioner, 114 T.C. 136, 140 (2000); Jenkins v.
Commissioner, T.C. Memo. 1989-618; Jenkins v. Commissioner, T.C.
Memo. 1989-617.
Petitioner has not shown that his failure to file valid
returns was due to reasonable cause. To the contrary, his
purported returns convince us that his failure to file valid
returns resulted from his deliberate attempt to subvert the tax
laws. Accordingly, we sustain respondent’s determination of
section 6651(a)(1) additions to tax as set forth in the notices
of deficiency.
2. Failure To Pay Estimated Tax
For each year at issue, respondent determined that
petitioner is liable for the section 6654 addition to tax for
underpaying required installments of individual estimated tax.
In his petition, the only argument that petitioner raises
that arguably pertains to the section 6654 addition to tax is
that “Since there is no additional income, it follows that the
additional claims for penalties are also in error.” Contrary to
petitioner’s argument, however, we have sustained respondent’s
deficiency determinations as to the amount of petitioner’s
unreported income for each year at issue. Petitioner does not
allege, and the evidence does not suggest, that any exception in
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