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4. 2001 and 2002
Because petitioner was not required to file a return for
either 2001 or 2002, he is not liable for an addition to tax
under section 6651(a) for either year.
B. Respondent’s Section 6654 Determination
Respondent determined that petitioner is liable for a
$111.21 addition to tax pursuant to section 6654 for 1999 for
failure to pay estimated tax.
Section 6654 provides for an addition to tax in the event of
an underpayment of a required installment of individual estimated
tax. Sec. 6654(a) and (b). Each required installment is equal
to 25 percent of the “required annual payment”, which, in turn,
is 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)(A),
(B)(i) and (ii). The due dates of the required installments for
a calendar taxable year are April 15, June 15, and September 15
of that year and January 15 of the following year. Sec.
6654(c)(2). An individual’s tax, for purposes of section 6654,
consists of income and self-employment tax determined before the
application of any wage withholding credits which, under section
6654(g)(1), are treated as payment of estimated tax. See sec.
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