10 burden of proving that his failure to file was due to reasonable cause and not willful neglect. See United States v. Boyle, supra. Petitioner did not offer evidence showing that he had reasonable cause for not filing his 1995 return. We conclude that petitioner is liable for the addition to tax under section 6651(a)(1) for failure to file his 1995 income tax return. C. Whether Petitioner Is Liable for the Addition to Tax for Failure To Pay Estimated Tax Respondent determined that petitioner is liable for the addition to tax under section 6654 for failure to pay estimated tax for 1995. We have jurisdiction to review this determination because petitioner did not file a return for 1995. Sec. 6665(b)(2); Meyer v. Commissioner, 97 T.C. 555, 562 (1991). To be liable for the addition to tax under section 6654, a taxpayer must have underpaid or failed to pay estimated tax for the year in issue. Sec. 6654(a). A taxpayer is liable for the addition to tax for failure to pay estimated tax unless the taxpayer shows that he or she meets one of the exceptions provided in section 6654(e), none of which apply here. Brown reviewed respondent’s administrative file in this case, and testified that petitioner made no tax payments forPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011