Dean Strom Karnaze - Page 9

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          bulk of the amount shown as tax on the return for each of the               
          years in issue remained unpaid as of the respective due dates.              
               Petitioner contends that he did not remit full payments for            
          the years in issue because of hardship due to his divorce and               
          subsequent loss of employment.  Petitioner has not shown that he            
          would have suffered substantial financial loss if he had paid his           
          taxes by the due date.  Moreover, adverse economic conditions do            
          not necessarily constitute reasonable cause because almost every            
          nonwillful failure to pay taxes is the result of financial                  
          difficulties.  See Estate of Hartsell v. Commissioner, T.C. Memo.           
          2004-211; Wolfe v. United States, 612 F. Supp. 605, 607-608 (D.             
          Mont. 1985), affd. on other grounds 798 F.2d 1241 (9th Cir.                 
          1986).                                                                      
               The Court therefore finds that petitioner failed to                    
          demonstrate that his failure to timely pay the taxes shown on the           
          returns for the years in issue 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.                                          
          Additions to Tax Under Section 6654                                         
               Section 6654 imposes an addition to tax for failure to make            
          timely and sufficient payments for estimated taxes.  In order for           
          respondent to satisfy his burden of production under section                






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