- 6 - Estimated Tax Requirement Petitioner also contends that there is no “enabling legislation” requiring payment of estimated taxes since the repeal of former section 6015 in 1984. Former section 6015, relating to declarations of estimated income tax by individuals, was repealed by section 412 of the Deficit Reduction Act of 1984 (DEFRA), Pub. L. 98-369, 98 Stat. 792. That repeal was contemporaneous with the amendment of section 6654 in DEFRA section 411. DEFRA sections 411 and 412, 98 Stat. 788, 792, were among the simplification provisions effectuated by consolidating into section 6654 all rules relating to payments of estimated tax. Sections 6654(c) and (d), as in effect for the years in issue, set forth the number of required installments and the amount of required installments of estimated tax due from individuals. Section 6654(a) imposes an addition to tax for failure to make the required payments. The addition to tax determined by respondent by reason of petitioner’s failure to make the estimated tax payments is mandatory, with exceptions not applicable in this case. See, e.g., Grosshandler v. Commissioner, 75 T.C. 1, 20-21 (1980). Section 6651(a) Finally, petitioner contends that her attempts to secure explanations from the IRS about her arguments were reasonablePage: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011