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document under penalties of perjury.8 On the instant record, we
find that petitioner’s document for 1996 is not a valid tax
return for that year. See United States v. Moore, 627 F.2d 830,
834 (7th Cir. 1980); Williams v. Commissioner, 114 T.C. 136, 139-
140 (2000); Sloan v. Commissioner, 102 T.C. 137, 143 (1994),
affd. 53 F.3d 799 (7th Cir. 1995); Cupp v. Commissioner, 65 T.C.
68, 78-79 (1975), affd. without published opinion 559 F.2d 1207
(3d Cir. 1977). On the record before us, we find that respondent
has carried respondent’s burden of production with respect to the
additions to tax under section 6651(a)(1) for the years at issue.
On that record, we further find that petitioner is liable for
each of those years for such an addition to tax.
With respect to the addition to tax under section 6654(a)
that respondent determined for each of the years at issue, the
record establishes that on April 18, 1996, petitioner made an
estimated tax payment for 1996 of $2,0009 and that petitioner
made no estimated tax payments for 1997.10 On the record before
us, we find that respondent has satisfied respondent’s burden of
8Petitioner struck from Form 1040 for 1996 that he used in
preparing petitioner’s document for 1996, inter alia, the decla-
ration that appeared above the place where he signed that docu-
ment.
9On Apr. 17, 1997, respondent also received a payment of
$25,624 from petitioner with respect to his taxable year 1996.
10The record also establishes that petitioner reported total
tax of $11,477 in the tax return that he filed for 1995.
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