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was repealed by section 412 of the Deficit Reduction Act of 1984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