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2000 contained petitioner’s name, address, Social Security
number, filing status, and information regarding income and tax,
to which was attached Form 886-A, Explanation Of Items,
containing sufficient information from which to compute
petitioner’s tax liability.
Petitioner did not show reasonable cause for the failure to
file timely returns for the years at issue or timely pay tax in
2000. Sec. 6651(a)(1) and (2). Accordingly, the Court finds
petitioner is liable for section 6651(a)(1) and (2) additions to
tax to be calculated under Rule 155.11
Under section 6654, the addition to tax is calculated with
reference to four required installment payments of the taxpayer’s
estimated tax liability. Each required installment of estimated
tax is equal to 25 percent of the “required annual payment”.
Sec. 6654(d)(1)(A). The “required annual payment” is generally
equal to the lesser of (1) 90 percent of the tax shown on the
individual’s return for that year (or, if no return is filed, 90
percent of his or her tax for such year), or (2) if the
individual filed a return for the immediately preceding taxable
year, 100 percent of the tax shown on that return. Sec.
6654(d)(1)(B); Wheeler v. Commissioner, 127 T.C. 200, 210-211
(2006); Heers v. Commissioner, T.C. Memo. 2007-10.
11 In the Rule 155 calculations the parties must take into
consideration sec. 6651(c)(1).
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Last modified: November 10, 2007