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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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