- 12 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011