Ronald E. Byers - Page 18




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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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