Richard Mark Hansen - Page 11

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          Swastika Oil & Gas Co. v. Commissioner, 123 F.2d 382 (6th Cir.              
          1941), affg. 40 B.T.A 798 (1939).                                           
               The Court finds that petitioner has not presented, and the             
          record does not show, any evidence to demonstrate that his tax              
          liability for 1997 was incorrect.  Respondent’s determination is            
          sustained.                                                                  
          B.   Additions to Tax                                                       
               1.   Section 6651(a)                                                   
               Respondent determined that petitioner is liable for                    
          additions to tax under section 6651(a)(1) for 1998 of $442.57 and           
          for 2000 of $382.50.  Respondent also determined that petitioner            
          is liable for additions to tax under section 6651(a)(2) for 1997            
          of $925.35, for 1998 of $245.88, and for 2000 of $272.                      
               Section 6651(a)(1) imposes an addition to tax for failure to           
          file a Federal income tax return by its due date, determined with           
          regard to any extension of time for filing previously granted.              
          The addition to tax equals 5 percent for each month that the                
          return is late, not to exceed 25 percent.  Sec. 6651(a)(1).                 
               Section 6651(a)(2) provides for an addition to tax for                 
          failure to pay taxes shown on a return on or before the payment             
          due date.  The addition to tax is one-half percent of the amount            
          shown as tax on a return for each month or fraction thereof                 
          during which the failure to pay continues, not exceeding 25                 
          percent in the aggregate.  Sec. 6651(a)(2).                                 






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