- 8 - With respect to the section 6651(a)(1) addition to tax for failure to file timely, we find that respondent has satisfied his burden of production. Respondent adduced a certified transcript of account for petitioner's 2001 taxable year, which shows that petitioner failed to file a return for that year. An information return, corroborated by Mr. Meadows's testimony, indicates petitioner received income of $56,718.99 in 2001, an amount that is sufficient to impose a return-filing obligation on petitioner. Sec. 6012. Petitioner has offered no evidence of reasonable cause or any other basis on which she would not be liable for the section 6651(a)(1) addition to tax. See Higbee v. Commissioner, supra. Respondent has also met his burden of production with respect to the section 6654 addition to tax for failure to pay estimated taxes. Petitioner's income tax deficiency for 2001 is sufficient to obligate her to make estimated tax payments. A certified transcript of account for petitioner's 2000 taxable year indicates that she also failed to file a return in that year. The certified transcript of account for 2001 indicates that petitioner had no withholding, made no estimated tax payments, and had no other credits or payments for 2001. The foregoing is sufficient evidence to satisfy respondent's burden of production under section 7491(c) with respect to the sectionPage: Previous 1 2 3 4 5 6 7 8 9 10 NextLast modified: November 10, 2007