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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
Division.
Decision will be entered
for respondent.
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Last modified: May 25, 2011