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petitioner is liable for the additions to tax pursuant to section
6651(a)(1) for 2000 and 2001.
B. Section 6654(a)
Section 6654(a) imposes an addition to tax “in the case of
any underpayment of estimated tax by an individual.” The amount
of the underpayment is the excess of the “required installment”
over the amount (if any) of the installment paid on or before the
due date of the installment. Sec. 6654(b)(1). The amount of the
required installment is 25 percent of the required annual
payment. Sec. 6654(d)(1)(A). Since petitioner filed no return
for 2000, the “required annual payment” for 2001 is 90 percent of
the tax for 2001. Sec. 6654(d)(1)(B).
Petitioner and his wife had total withholding in the amount
of $994 and made no estimated tax payments for 2001. Respondent
conceded that petitioner’s corrected income for 2001 is $46,155.
After allowing the standard deduction ($4,550) and exemptions
($2,900) contained in the notice of deficiency, petitioner’s
total “corrected taxable income” for 2001 equals $38,705.
According to the 2001 tax table, available on the Internal
Revenue Service’s Web site, the tax due for an individual with
$38,705 of taxable income and married filing separately status is
$7,824. See Fed. R. Evid. 201 (regarding judicial notice).
Petitioner’s total withholding, even before reducing it by one-
half pursuant to section 1.31-1(a), Income Tax Regs., and
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