Johny L. Dotson - Page 6

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          addition to tax under section 6654 for failure to pay estimated             
          taxes for 1999.  Section 6654(c) imposes a requirement that                 
          estimated taxes be paid in installments.  If a taxpayer fails to            
          pay a sufficient amount of estimated taxes, section 6654(a)                 
          provides for a mandatory addition to tax in the absence of                  
          exceptions not applicable here.  Grosshandler v. Commissioner, 75           
          T.C. 1, 20-21 (1980).  Petitioner did not file a tax return for             
          1999, and there is no evidence that any tax was withheld from the           
          income he received in 1999.  Accordingly, we find that petitioner           
          is liable for the addition to tax under section 6654 for 1999.              
               Reviewed and adopted as the report of the Small Tax Case               

                                                  Decision will be entered            
                                             for respondent.                          

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