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Petitioner introduced no evidence or any legally sufficient
reason for his failure to file a timely return. Therefore, the
Court finds that petitioner did not have reasonable cause for his
failure to file as required by section 6651(a)(1) and he is
liable for the additions to tax as respondent determined.
Additions to Tax Under Section 6654
Respondent also contends that petitioner is liable for the
additions to tax under section 6654 for 1996, and 1997. Section
6654 provides an addition to tax for failure to make timely and
sufficient payments for estimated taxes. The section 6654
addition to tax is mandatory unless petitioner can place himself
within one of the computational exceptions provided by section
6654. Recklitis v. Commissioner, 91 T.C. 874, 913 (1988);
Grosshandler v. Commissioner, 75 T.C. 1, 20-21 (1980). Since
petitioner has failed to do so, this Court sustains respondent on
this issue.
Reviewed and adopted as the report of the Small Tax Case
Division.
To reflect the foregoing,
Decision will be entered
for respondent as to the
deficiencies and the additions
to tax under section
6651(a)(1) for 1995, 1996, and
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