- 20 - Accordingly, we find that there is an additional deficiency in tax with respect to Dr. Trowbridge for 1996 based on gross business receipts of $1,632,140 for that year. V. Additions to Tax A. Statutory Provisions 1. Section 6651(a)(1) Section 6651(a)(1) provides for an addition to tax in the event a taxpayer fails to file a timely return (determined with regard to any extension of time for filing), unless it is shown that such failure is due to reasonable cause and not due to willful neglect. The amount of the addition is equal to 5 percent of the amount required to be shown as tax on the delinquent return for each month or fraction thereof during which the return remains delinquent, up to a maximum addition of 25 percent for returns more than 4 months delinquent. For these purposes, the amount required to be shown as tax on the return is reduced by any timely payments of the tax16 and any credits which may be claimed on the return. Sec. 6651(b)(1). 2. Section 6654 Section 6654 provides for an addition to tax (in the form of an interest charge) in the event of an underpayment of a required installment of individual estimated tax. As relevant to this 16 In general, payment of income tax is due on the due date of the corresponding return, determined without regard to any filing extensions. Sec. 6151(a).Page: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Next
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