-21-
or was filed late. Mendes v. Commissioner, 121 T.C. 308, 324
(2003).
It was deemed admitted under Rule 37(c) that petitioner
failed to file a Federal income tax return for 2003. It was
further admitted that petitioner failed to make required
estimated Federal income tax payments for 2003. Petitioner did
not qualify for an exception to application of section 6654. We
therefore hold that petitioner is liable for an addition to tax
under section 6654 for 2003 determined with respect to the tax
shown on his 2002 return, $3,319.
In reaching our holdings, we have considered all arguments
made, and, to the extent not mentioned, we conclude that they are
moot, irrelevant, or without merit.
To reflect the foregoing,
Decision will be
entered under Rule 155.
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Last modified: November 10, 2007