- 11 - 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., andPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011