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Petitioner has not provided any evidence that his failure to file
was due to reasonable cause. Therefore, the Court sustains the
imposition of an addition to tax under section 6651(a)(1).
Section 6654(a) provides for an addition to tax for failure
to pay estimated income tax where there has been an underpayment
of estimated taxes by a taxpayer. In general, taxes withheld on
wages will be deemed a payment of estimated tax with an equal
part of such amount withheld deemed paid on each due date for
such taxable year. Sec. 6654(g)(1). The record indicates that
petitioner made estimated tax payments for 2000 in the amount of
$21,889. However, the correct payment amount for 2000 was
$26,955.50, and the Court finds that petitioner’s estimated tax
payments were not sufficient to avoid an addition to tax.
Petitioner did not appear at trial or submit a brief, and he has,
therefore, not demonstrated that his situation falls within any
of the specified exceptions under section 6654(e). Therefore,
the Court will enter a decision that petitioner is also liable
for this addition to tax in the amount of $300.70 as computed in
respondent’s Exhibit 6-R.
IV. Section 6673 Penalty
Section 6673 allows this Court to award a penalty to the
United States in an amount not in excess of $25,000 for
proceedings instituted by the taxpayer primarily for delay or for
proceedings in which the taxpayer’s position is frivolous or
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Last modified: May 25, 2011