Charles H. Little III - Page 9

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          payments of his taxes for the year at issue.  Under section                 
          6654(d), the amount of the four quarterly installments (including           
          taxes withheld) generally must equal 90 percent of the tax for              
          the year, or 100 percent of the tax for the preceding taxable               
          year, whichever is less.  The Court, therefore, sustains                    
          respondent on this issue.                                                   
               Reviewed and adopted as the report of the Small Tax Case               
          Division.  Due to the agreed reduced deficiency, the additions to           
          tax must be recalculated.  Accordingly,                                     

          Decision will be entered                                                    
          under Rule 155.                                                             

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Last modified: May 25, 2011