- 10 -
substantial authority. Higbee v. Commissioner, 116 T.C. 438, 446
(2001); H. Conf. Rept. 105-599, supra at 241, 1998-3 C.B. at 995.
Petitioner did not file returns for 1998-2001, and he did
not make estimated tax payments with respect to his tax liability
for those years. There is no evidence that petitioner paid any
tax for the years in issue. Thus, respondent has met the burden
of production, and petitioner is liable for additions to tax for
failure to file under section 6651(a)(1) of $1,241.55 for 1998,
$1,144.80 for 1999, $798.08 for 2000, and $992.25 for 2001, and
additions to tax under section 6654 for failure to pay estimated
tax of $250.45 for 1998, $244.35 for 1999, $190.77 for 2000, and
$174.52 for 2001.
To reflect the foregoing,
Decision will be
entered for respondent.
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Last modified: May 25, 2011