- 14 - Because respondent conceded that petitioner had no tax liability for the year 1988, it follows that petitioner is not liable for the addition to tax under section 6654 for the year 1989. Sec. 6654(e)(2). Although petitioner did not make any estimated tax payments during any of the years in issue, it appears that some of petitioner's employers withheld Federal income taxes from the wages paid to him. Whether the conditions necessary for the imposition of the addition to tax exist with respect to the other years, and if so whether any exception applies, can only be determined after the Rule 155 computations have been submitted. To reflect the foregoing, Decision will be entered under Rule 155.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14
Last modified: May 25, 2011