- 7 - The documents petitioner submitted for tax years 1999 and 2000 are not recognized by respondent as returns because they do not constitute Forms 1040 and they fail to provide any information required by Form 1040, specifically the amount of petitioner's income for each year. None of the documents submitted by petitioner constitute returns. Therefore, petitioner has yet to file any returns. Petitioner has not offered any evidence that his failure to file is due to reasonable cause and not to willful neglect. Respondent's determinations that petitioner is liable for the additions to tax under section 6651(a)(1) are sustained. Respondent also determined an addition to tax under section 6654 for petitioner's underpayment of estimated tax for 1999 and 2000. This addition to tax is mandatory and automatic, subject to certain exceptions provided by section 6654(e). Grosshandler v. Commissioner, 75 T.C. 1 (1980). Petitioner failed to offer any evidence that he fits within any of the listed exceptions. Respondent's determinations that petitioner is liable for section 6654 additions to tax are sustained. Petitioner did not introduce any evidence to show that he is not liable for the income tax deficiencies and additions to tax under sections 6651(a)(1) and 6654; accordingly, respondent's determinations for all 4 years are sustained.Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011