- 9 - Memo. 1983-684. Thus, we sustain respondent’s determination that petitioner’s wages constitute gross income under section 61(a). 2. Additions to Tax a. Section 6651 Respondent determined that petitioner is liable for additions to tax for: (1) Failure to file a timely return for taxable year 2001 pursuant to section 6651(a)(1); and (2) failure to file a timely return for taxable year 2002 pursuant to section 6651(a)(1). Section 6651(a)(1) imposes an addition to tax for failure to timely file a tax return. The addition to tax is equal to 5 percent of the amount of the tax required to be shown on the return if the failure to file is not for more than 1 month. See sec. 6651(a)(1). An additional 5 percent is imposed for each month or fraction thereof in which the failure to file continues, to a maximum of 25 percent of the tax. See id. Section 6651(a)(2) provides for an addition to tax of 0.5 percent per month, up to 25 percent, for failure to pay the amount shown or required to be shown on a return. A taxpayer may be subject to both paragraphs (1) and (2), in which case the amount of the addition to tax under section 6651(a)(1) is reduced by the amount of the addition to tax under section 6651(a)(2) for any month to which an addition to tax applies under both paragraphs (1) andPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
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