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section 6654 for 2003. Section 6654 imposes an addition to tax
on an individual taxpayer who underpays his estimated tax. The
addition to tax is calculated with reference to four required
installment payments of the taxpayer’s estimated tax liability.
Sec. 6654(c)(1); Wheeler v. Commissioner, supra. 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, supra. The
due dates of the required installments for a calendar year
taxpayer are April 15, June 15, and September 15 of the calendar
year in question and January 15 of the following year. Sec.
6654(c)(2); Wheeler v. Commissioner, supra.
Respondent produced evidence establishing that petitioner
did not file a return for 2003 and that petitioner had an income
tax liability of $9,619.40 for 2003. The evidence was sufficient
to permit the Court to make the analysis required by section
6654(d)(1)(B)(i). See Wheeler v. Commissioner, supra. Because
petitioner did not file a return for the preceding taxable year,
2002, respondent has met his burden of producing evidence that
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