Wilson D. Watson - Page 25




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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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