Omar Urbina Pineda - Page 17

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          he would have suffered substantial loss if he had paid his taxes            
          by the due date.  We also observe that adverse economic                     
          conditions do not necessarily constitute reasonable cause because           
          almost every nonwillful failure to pay taxes is the result of               
          financial difficulties.  See Wolfe v. United States, 612 F.Supp.            
          605, 607-608 (D. Mont. 1985), affd. on other grounds 798 F.2d               
          1241 (9th Cir. 1986).                                                       
               We therefore conclude that petitioner failed to demonstrate            
          that his failure to timely pay tax shown on his returns was due             
          to reasonable cause and not willful neglect.  See sec. 301.6651-            
          1(c), Proced. & Admin. Regs.; sec. 1.6161-1(b), Income Tax Regs.            
          Accordingly, petitioner is liable for the additions to tax under            
          section 6651(a)(2) for the years in issue.                                  
               We next address the addition to tax under section 6654 for             
          the taxable year 2001.  Section 6654(a) imposes an addition to              
          tax for failure to make timely estimated income tax payments.               
          Section 6654(e) contains several computational exceptions to                
          application of the addition to tax.  As relevant herein, there is           
          no addition to tax under section 6654(a) if the tax shown on the            
          return is less than $1,000, sec. 6654(e)(1), or the taxpayer did            
          not have any liability for tax for the preceding taxable year,              
          sec. 6654(e)(2).                                                            
               Petitioner bears the burden of proving that he paid                    
          estimated tax or that any of the exceptions excuse him from                 






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