(e) Exceptions. -
1.Where tax is small amount. -- No addition to tax shall be imposed under subsection (a) for any taxable year if the tax shown on the return for such taxable year (or, if no return is filed, the tax), reduced by the credit allowable under section 31, is less than $500.
2.Where no tax liability for preceding taxable year.--No addition to tax shall be imposed under subsection (a) for any taxable year if --
A. The preceding taxable year was a taxable year of 12 months.
B. The individual did not have any liability for tax for the preceding taxable year,
and
C. The individual was a citizen or resident of the United States throughout the preceding taxable year . (emphasis added)
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