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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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Last modified: May 25, 2011