Rita Grant Ndirika - Page 18

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          6651(a)(1).  On that record, we further find that petitioner has            
          failed to carry her burden of showing that her failure to file a            
          tax return for 2000 was due to reasonable cause, and not due to             
          willful neglect.                                                            
               Respondent conceded in the answer the addition to tax under            
          section 6651(a)(2) determined in the notice.  As a result,                  
          according to respondent, section 6651(c)(1) does not apply.  We             
          agree with respondent.  On the record before us, we find that               
          respondent has established that the amount of the addition to tax           
          under section 6651(a)(1) that respondent determined in the notice           
          should be increased.8                                                       
          Addition to Tax Under Section 6654(a)                                       
               Respondent determined that petitioner is liable for the                
          addition to tax under section 6654(a).  Section 6654(a) imposes             
          an addition to tax in the case of an underpayment of estimated              
          tax by an individual.9                                                      


               8The increase in the addition to tax under 6651(a)(1) that             
          we have sustained will be determined by the parties under Rule              
          155.                                                                        
               9For purposes of sec. 6654(a), it is necessary to determine            
          whether there is an underpayment of a required installment of               
          estimated tax.  See sec. 6654(a) and (b).  In this connection,              
          the amount of any required installment is 25 percent of the                 
          required annual payment.  Sec. 6654(d)(1)(A).  The required                 
          annual payment is equal to the lesser of (1) 90 percent of the              
          tax shown in the tax return for the taxable year or, if no tax              
          return was filed, 90 percent of the tax for such year, or (2) if            
          the individual filed a tax return for the preceding taxable year,           
          100 percent of the tax shown in such return.  Sec. 6654(d)(1)(B).           





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