James Carlyle Maloney, Jr. - Page 7

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          estimated tax payments.  Section 6654(a) provides for an addition           
          to tax where a taxpayer underpays estimated tax.  Respondent’s              
          certified transcript of account establishes that petitioner made            
          no estimated tax payments during 2000, and none of the statutory            
          exceptions under section 6654(e) applies.  We therefore find that           
          petitioner is liable for the addition to tax under section                  
          6654(a) for underpaying estimated tax in 2000.                              
               To reflect the foregoing regarding the deficiency, additions           
          to tax, and respondent’s concession,                                        


                                                  Decision will be entered            
                                             for respondent.                          


























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