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Addition to Tax Under Section 6654
Petitioner underpaid his estimated tax for the year, and
respondent has carried his burden of production to show that it
is appropriate to impose the addition to tax. The section 6654
addition to tax applies in a mathematical fashion unless it is
shown that any of certain statutory exceptions apply. See
Grosshandler v. Commissioner, 75 T.C. 1, 20-21 (1980); Goers v.
Commissioner, T.C. Memo. 1999-354. Petitioner has not shown that
any exceptions apply. Accordingly, respondent’s determination
that petitioner is liable for an addition to tax under section
6654 is sustained.
Reviewed and adopted as the report of the Small Tax Case
Division.
To reflect the foregoing,
Decision will be
entered under Rule 155.
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Last modified: May 25, 2011