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B. Section 6654
Section 6654(a) provides for an addition to tax for failure
to pay estimated income tax where there has been an underpayment
of estimated taxes by a taxpayer. In general, taxes withheld on
wages will be deemed a payment of estimated tax with an equal
part of such amount withheld deemed paid on each due date of a
required installment of estimated tax for such taxable year.
Sec. 6654(g)(1). The record indicates that petitioner had
amounts withheld from his compensation for 1994, 1995, 1996,
1997, 1998, 1999, and 2000; however, petitioner still had an
underpayment of estimated taxes. At trial, petitioner did not
make any arguments or offer any evidence to demonstrate that his
situation falls within any of the specified exceptions under
section 6654(e). For taxable year 2001, petitioner conceded at
trial the amount of the section 6654 addition to tax. Therefore,
petitioner is liable for this addition to tax for all the years
in issue.
VII. Section 6673 Penalty
Section 6673 allows this Court to award a penalty to the
United States in an amount not in excess of $25,000 for
proceedings instituted by the taxpayer primarily for delay or for
proceedings in which the taxpayer’s position is frivolous or
groundless. “A petition to the Tax Court, or a tax return, is
frivolous if it is contrary to established law and unsupported by
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