Glenn S. Hodges - Page 12

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               B.  Respondent's Section 6654 Determination                            
               Section 6654 provides for an addition to tax in the event of           
          an underpayment of a required installment of individual estimated           
          tax.  Sec. 6654(a) and (b).  As relevant to this case, each                 
          required installment of estimated tax is equal to 25 percent of             
          the "required annual payment", which in turn is equal to the                
          lesser of (1) 90 percent of the tax shown on the individual's               
          return for that year (or, if no return is filed, 90 percent of              
          his or her tax for such year), or (2) if the individual filed a             
          return for the immediately preceding taxable year, 100 percent of           
          the tax shown on that return.  Sec. 6654(d)(1)(A) and (B)(i) and            
          (ii).  The due dates of the required installments for a calendar            
          taxable year are April 15, June 15, and September 15 of that year           
          and January 15 of the following year.  Sec. 6654(c)(2).                     
               Petitioner filed no return for 1999 or 2000.  Petitioner’s             
          “required annual payment” of estimated tax was, therefore, equal            
          to 90 percent of his tax for 2000.  Petitioner paid none of the             
          required installments of that amount.                                       
               We sustain an addition to tax under section 6654(a) in the             
          amount of $4,519.3                                                          





               3  Petitioner does not challenge the computation of the sec.           
          6654 addition to tax, which we have not computed.                           





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