- 12 - Section 6654(a) The section 6654 addition to tax for failure to pay estimated tax is mandatory unless the taxpayer establishes that a statutory exception applies. Grosshandler v. Commissioner, 75 T.C. 1, 20-21 (1980). Mr. Stafford is deemed to have stipulated that additions to tax under section 6654(a) for 1989 and 1990 are due from him because he underpaid his estimated tax for both years. Accordingly, there is no genuine issue of material fact as to this issue, and respondent's motion for summary judgment thereon with respect to Mr. Stafford will be granted. Section 6662(a) Section 6662(a) imposes a 20-percent penalty on the portion of an underpayment attributable to, inter alia, negligence or disregard of rules or regulations.5 Mrs. Stafford is deemed to have stipulated that the section 6662(a) penalties are due from her for the underpayment of tax for 1989 and 1990. Accordingly, there is no genuine issue of material fact regarding Mrs. Stafford's liability for these penalties, and respondent's motion for summary judgment thereon will be granted. 3. The Section 6673 Penalty Petitioners are advised of the provisions of section 6673 giving this Court authority to impose a penalty of up to $25,000 5 Respondent determined in the notice of deficiency with respect to Mrs. Stafford that all or part of the underpayment for 1990 and 1991 is due to negligence or intentional disregard of rules or regulations.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011