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.