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Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the year in issue.
Background
As a result of an error by petitioner in the computation of
his estimated income tax due January 15, 1999, petitioner
underpaid estimated income tax for the last quarter of 1998 by
approximately $11,000. Upon recognizing the error, on
February 14, 1999, petitioner filed early his individual Federal
income tax return for 1998, and petitioner paid the above
$11,000, plus additional taxes owed.
On September 20, 1999, respondent indicated by letter to
petitioner that petitioner owed $594 as an addition to tax under
section 6654(a) relating to petitioner's $11,000 underpayment of
estimated income tax for the last quarter of 1998 and that
petitioner owed $5 of interest with respect thereto.
On October 29, 1999, by letter to respondent's Office of the
Taxpayer Advocate in Memphis, Tennessee, petitioner requested
that, based on his unblemished record in years before 1998 of
full compliance with Federal tax laws, the $594 addition to tax
be waived and that the $5 of interest be abated.
On December 9, 1999, respondent mailed a letter to
petitioner explaining generally how additions to tax for
underpayment of estimated income taxes are computed.
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