No Tax Liability Last Year
You do not owe a penalty if you had no tax liability last year and you were a U.S. citizen or resident for the whole year. For this rule to apply, your tax year must have included all 12 months of the year.
You had no tax liability for 2008 if your total tax was zero or you were not required to file an income tax return.
Example.
Ray, who is single and 22 years old, was unemployed for most of 2008. He earned $2,700 in wages before he was laid off, and he received $2,500 in unemployment compensation afterwards. He had no other income. Even though he had gross income of $5,200, he did not have to pay income tax because his gross income was less than the filing requirement for a single person under age 65 ($8,950 for 200

. He filed a return only to have his withheld income tax refunded to him.
In 2009, Ray began regular work as an independent contractor.
Ray made no estimated tax payments in 2009. Even though he did owe tax at the end of the year, Ray does not owe the underpayment penalty for 2009 because he had no tax liability in 2008.
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