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B. Respondent's Section 6654 Determination
Section 6654 provides for an addition to tax in the event of
an underpayment of a required installment of individual estimated
tax. Sec. 6654(a) and (b). As relevant to this case, each
required installment of estimated tax is equal to 25 percent of
the "required annual payment", which in turn is equal to the
lesser of (1) 90 percent of the tax shown on the individual's
return for that year (or, if no return is filed, 90 percent of
his or her tax for such year), or (2) if the individual filed a
return for the immediately preceding taxable year, 100 percent of
the tax shown on that return. Sec. 6654(d)(1)(A) and (B)(i) and
(ii). The due dates of the required installments for a calendar
taxable year are April 15, June 15, and September 15 of that year
and January 15 of the following year. Sec. 6654(c)(2).
Petitioner filed no return for 1999 or 2000. Petitioner’s
“required annual payment” of estimated tax was, therefore, equal
to 90 percent of his tax for 2000. Petitioner paid none of the
required installments of that amount.
We sustain an addition to tax under section 6654(a) in the
amount of $4,519.3
3 Petitioner does not challenge the computation of the sec.
6654 addition to tax, which we have not computed.
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