Rebecca A. Peck - Page 5

          liable for such addition for the year 1991.  In the returns for             
          1990 and 1991, which are in evidence herein and which respondent            
          has agreed are correct as to all items of income and deduction              
          other than the disputed dependency exemptions for children                  
          mentioned above, practically all of petitioner's reported gross             
          income was subject to withholding in 1991, in the total amount of           
          $9,418.  The amount of $205 was also an excessive withholding               
          from petitioner on account of Social Security or Medicare                   
          resulting in total tax having been withheld from petitioner for             
          1991 in the amount of $9,623.  Such withholding would be                    
          creditable by petitioner against her 1991 tax liability as though           
          paid in four equal installments in 1991, under the provisions of            
          section 6654(g).  In the necessary recomputation of liability for           
          the years 1990 and 1991, which will result from our decision and            
          the parties' agreement in this case, it may turn out that                   
          withholdings from petitioner will be enough to satisfy her                  
          liability for tax for 1991, pursuant to section 6654(g).  It may            
          also turn out that such payments will satisfy the requirements of           
          section 6654(d), in that the payments made for the year 1991 will           
          constitute at least 90 percent of the tax for 1991 as finally               
          redetermined by the parties, or will constitute 100 percent of              
          the tax that has been recomputed to be owing for the year 1990.             
          Sec. 6654(d)(1)(B).  If such requirements are not met, however,             
          petitioner will owe some addition to tax for the year 1991 under            
          section 6654.  The requirements of that section are mandatory,              

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