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VII. Section 6654 Addition to Tax
Section 6654(a) provides for an addition to tax in the case
of any underpayment of estimated tax by an individual. Where
payments of tax, through either withholding or the making of
estimated quarterly tax payments, do not equal the percentage of
total liability required under the statute, imposition of the
addition is automatic and mandatory, unless one of the statutory
exceptions enumerated in section 6654 is shown by the taxpayer to
apply. Sec. 6654(a)-(e), (g); Grosshandler v. Commissioner, 75
T.C. 1, 20-21 (1980). Since petitioner paid no estimated taxes
and has offered no evidence indicating any of the exceptions to
be applicable here, we sustain respondent on this issue for each
of the taxable years under consideration.
To reflect the foregoing and the parties’ concessions,
Decision will be entered
under Rule 155.
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