- 15 - III. Section 6654 Respondent determined that petitioners underpaid their estimated income tax and are liable for additions to tax under section 6654. Where payments of tax, either through withholding or by making estimated tax payments, do not equal the percentage of the total liability required under the statute, imposition of the addition to tax under section 6654 is automatic, absent a showing that the taxpayer has met one of the exceptions contained therein. Recklitis v. Commissioner, 91 T.C. 874, 913 (1988); Tillman v. Commissioner, T.C. Memo. 1996-8. Petitioners have not shown that any of the exceptions apply. We sustain respondent's determination on this issue. We have considered all of petitioners' arguments in this case, and, to the extent not discussed above, find them to be irrelevant or without merit. To reflect the foregoing, Decisions will be entered under Rule 155.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15
Last modified: May 25, 2011