David Jackson and Betty S. Jackson - Page 18

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          all additions to tax.                                                       
               In the alternative, petitioners contend that respondent                
          should abate the addition to tax for late payment that accrued              
          from March 27 through July 30, 2003.10  Petitioners assert that             
          they would have paid their outstanding tax liabilities on or                
          about March 27, 2003, but that respondent failed to timely                  
          provide them with an escrow demand letter.  Petitioners’                    
          contention is misplaced.                                                    
               Section 6651(a)(2) imposes an addition to tax for failure to           
          pay the amount shown as tax on the return on or before the date             
          prescribed for payment of that tax, unless the failure was due to           
          reasonable cause and not willful neglect.  See sec. 301.6651-               
          1(c)(1), Proced. & Admin. Regs.  Petitioners may demonstrate                
          reasonable cause for late payment by showing that they exercised            
          ordinary business care and prudence in providing for payment of             
          their tax liability and were nevertheless either unable to pay              
          the tax or would suffer an undue hardship if they paid on the due           
          date.  Sec. 301.6651-1(c), Proced. & Admin. Regs.                           
               At the time that petitioners filed their returns, they                 
          failed to remit the amount shown as tax.  Based on the entirety             


               10  Petitioners concede that they are liable for the                   
          additions to tax for failure to timely file and for failure to              
          pay estimated tax.  Petitioners, however, contend that respondent           
          should have also abated the addition to tax for failure to pay              
          from July 31 to Nov. 30, 2003.  We note that this addition for              
          those years did not accrue for that period.  See sec. 6651(a)(2).           





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