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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