Anne M. Rogers - Page 6




                                        - 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          was repealed by section 412 of the Deficit Reduction Act of 1984            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 reasonable               






Page:  Previous  1  2  3  4  5  6  7  Next

Last modified: May 25, 2011