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3. Petitioner Is Liable for Section 6654(a) Additions to
Tax
Section 6654(a) imposes an addition to tax on an
underpayment of estimated tax unless one of the statutory
exceptions applies. Niedringhaus v. Commissioner, 99 T.C. 202,
222 (1992); Grosshandler v. Commissioner, 75 T.C. 1, 20-21
(1980); see sec. 6654(e). Respondent’s Forms 4340 indicate that
petitioner did not make estimated tax payments in 1999 or 2000,
which petitioner confirmed in her testimony at trial. We find
that respondent has met his burden of production.
Under section 6654(e)(3)(B), the addition to tax will not be
imposed where the taxpayer becomes disabled in the taxable year
for which the estimated payments were required to be made or in
the preceding taxable year, and the underpayment is due to
reasonable cause and not due to willful neglect.
Petitioner was suffering from bilateral tendinitis, carpal
tunnel syndrome, and depression at the time the estimated
payments were required to be made. However, during this period,
petitioner was employed by Cypress and was running her own
startup network marketing business. We find that petitioner was
not disabled for purposes of section 6654. Therefore, the
exception found in section 6654(e)(3)(B) does not apply.
We do not find that any other statutory exception applies.
Therefore, we hold that petitioner is liable for additions to tax
under section 6654(a) for 1999 and 2000.
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Last modified: May 25, 2011