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section 6654(a) for taxable year 2000. Section 6654(a) provides
that in the case of an underpayment of estimated tax by an
individual, there shall be added to the tax an amount determined
by applying the underpayment rate established under section 6621
to the amount of the underpayment for the period of the
underpayment. Unless the taxpayer demonstrates that one of the
statutory exceptions applies, imposition of the section 6654(a)
addition to tax is mandatory where prepayments of tax, either
through withholding or by making estimated quarterly tax payments
during the course of the taxable year, do not equal the
percentage of total liability required under the statute. See
sec. 6654(a); Niedringhaus v. Commissioner, supra at 222.
The amount of the addition to tax under section 6654(a)
stated in the notice of deficiency is based on the return
respondent prepared for petitioner before the issuance of the
notice of deficiency. Nothing in the record indicates petitioner
made the required amount of estimated tax payments for taxable
year 2000. Petitioner has not shown that he falls within any of
the exceptions to the section 6654(a) addition to tax. See sec.
6654(e); Grosshandler v. Commissioner, 75 T.C. 1, 20-21 (1980).
Accordingly, we conclude petitioner is liable for the addition to
tax pursuant to section 6654(a) for taxable year 2000.
Reviewed and adopted as the report of the Small Tax Case
Division.
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