- 14 - 1.6654-1(a), Income Tax Regs. However, no addition to tax is imposed under section 6654(a) if one of the exceptions set forth in section 6654(e) is satisfied. Under section 6654(e)(2), no addition to tax is imposed under section 6654(a) if: (1) The taxpayer's preceding taxable year was a taxable year of 12 months; (2) the taxpayer did not have any tax liability for the preceding taxable year; and (3) the taxpayer was a citizen or resident of the United States throughout the preceding taxable year. Petitioner's 1992 taxable year was a taxable year of 12 months. Petitioner's joint Federal income tax return for the taxable year 1992, as stipulated to by the parties, reflects zero tax liability. In addition, petitioner was a resident of the United States throughout 1992. Consequently, the exception under section 6654(e)(2) applies with respect to the 1993 taxable year. We hold that petitioner is not liable for the addition to tax under section 6654(a). We have considered all of petitioner's arguments and, to the extent not discussed above, find them to be without merit. 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