- 22 - 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required individual taxpayers to file annual declarations of estimated income tax in certain circumstances and was repealed by the Deficit Reduction Act of 1984 (DEFRA), Pub.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 ofPage: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Next
Last modified: May 25, 2011