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6654(d) sets forth the amount of the required estimated tax
payments an individual must make to avoid the addition to tax
imposed by section 6654(a).
Respondent determined that petitioner is liable for an
addition to tax under section 6654(a) for the taxable years 1996
and 1999. Petitioner contends that since the repeal of former
section 6015 in 1984, there is no “authority” to impose an
addition to tax for failure to make estimated tax payments but
makes no other argument regarding the application of section
6654.
We rejected an identical argument in Rogers v. Commissioner,
T.C. Memo. 2001-20, affd. without published opinion 281 F.3d 1278
(5th Cir. 2001). Former section 6015(d) required individual
taxpayers to file annual declarations of estimated income tax in
certain circumstances and was repealed by the Deficit Reduction
Act of 1984 (DEFRA), Pub. L. 98-369, sec. 412(a)(1), 98 Stat.
792, for taxable years beginning after 1984. The obligation to
make estimated tax payments and the addition to tax for
underpayment of the estimated tax remained in effect, however,
for subsequent taxable years pursuant to sections 411 and 412 of
DEFRA, 98 Stat. 788-793, which consolidated the rules pertaining
to the payment of estimated income tax into section 6654.
Petitioner admits that he failed to make any payments of
estimated tax for 1996 or 1999, and no exception relieving him of
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