Stephanie K. Mills - Page 8




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               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 section             








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