- 7 - return for the year at issue. Although additions to tax were abated for petitioner’s prior years, the Court sees no basis for an abatement for the year at issue. The Court, moreover, has no obligation to abate the additions to tax simply because they were abated for prior years. Respondent is sustained on this issue. The final issue is respondent’s determination that petitioner is liable for the addition to tax under section 6654(a) for failure to pay estimated tax. This addition to tax is applicable where there is an underpayment of estimated tax, subject to exceptions or waivers that are not applicable here. Sec. 6654(e). The provisions of this section are mandatory where there is an underpayment of tax as determined under section 6654. This section contains no exonerating provisions, such as reasonable cause or lack of willful neglect. Estate of Ruben v. Commissioner, 33 T.C. 1071, 1072 (1960). In general, estimated income tax payments are used to provide for payment of income taxes not collected through withholding. Section 6654(c) provides for quarterly installments. Income taxes withheld from salaries or wages apply toward the amount of each required quarterly installment; however, to the extent withholdings do not satisfy the required quarterly installments, the taxpayer is required to make supplemental quarterly payments of estimated taxes. Sec. 6654(f). Since petitioner was self-employed, he was required to make estimated payments. He did not make estimatedPage: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011