- 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).
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