BobKamman
Level 15

For what it's worth, here is what the Internal Revenue Manual says about the situation:

Changes in Filing Status
  1. Taxpayers filing jointly in one of two successive years, but separately in the other, cannot, without modification, use the preceding year's tax when determining the lesser of current or prior year tax:

    1. Taxpayers filing jointly, who filed separately in the preceding taxable year, are to add the two separate tax liabilities in the preceding year for the purpose of computing their required annual payment.

    2. Taxpayers filing separately, who filed jointly in the preceding taxable year, are to compute their required annual payment by redetermining their separate share of the joint liability for the preceding year using each spouse's separate income and deductions based on the current year's filing status. For more information, see Publication 505, Chapter 4, General Rule.

  2. Taxpayers filing separately, who filed jointly in the preceding taxable year, are instructed to file Form 2210 with their return. If Form 2210 is not attached to the return, IRS will compute the penalty under the presumption that 100% of the preceding taxable year's tax was attributable to the income of that taxpayer.

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