- 24 - report the income listed on the 1988 information returns mailed to him. We sustain respondent’s determination under section 6653(a)(1). C. Respondent’s Section 6654 Determination 1. Introduction Section 6654 provides for an addition to tax in the event of an underpayment of a required installment of individual estimated tax. Sec. 6654(a) and (b). As relevant to this case, each required installment of estimated tax is equal to 25 percent of the “required annual payment”, which in turn is equal to the lesser of (1) 90 percent of the tax shown on the individual’s return for that year (or, if no return is filed, 90 percent of his or her tax for such year), or (2) if the individual filed a return for the immediately preceding taxable year, 100 percent of the tax shown on that return. Sec. 6654(d)(1)(A), (B)(i) and (ii). The due dates of the required installments for a calendar taxable year are April 15, June 15, and September 15 of that year and January 15 of the following year. Sec. 6654(c)(2). For purposes of section 6654, an individual’s tax consists of income tax and self-employment tax and is determined before the application of any wage withholding credit12 (but after the 12 Under sec. 6654(g)(1), wage withholding credits are treated as payments of estimated tax.Page: Previous 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 Next
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