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Under section 6651(a)(1), a taxpayer who fails to file a
Federal income tax return by the date due may be liable for an
addition to tax unless the taxpayer demonstrates reasonable cause
and not willful neglect.
Generally, a taxpayer who is required to pay but who
significantly underpays estimated Federal income taxes shall be
liable for an addition to tax. Sec. 6654(a).
Petitioner admits that he had no reasonable cause for his
failure to file Federal income tax returns for the years in
issue. We sustain respondent’s determination of section
6651(a)(1) failure to file additions to tax and section 6654
estimated tax additions to tax against petitioner for 1999, 2000,
2001, and 2002.
We have considered all arguments made herein, and, to the
extent not addressed, we conclude that they are without merit or
are irrelevant.
To reflect the foregoing,
Decision will be entered
for respondent.
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Last modified: March 27, 2008