Leon Albert Landry - Page 4

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            without merit.  The notice was mailed to and actually received by                         
            petitioner at his last known address.  Sec. 6212(b); see Erhard                           
            v. Commissioner, 87 F.3d 273 (9th Cir. 1996), affg. T.C. Memo.                            
            1994-344; Frieling v. Commissioner, 81 T.C. 42, 53 (1983).  We                            
            find that the notice is valid and turn to the question of whether                         
            respondent correctly determined petitioner's tax liability.                               
                  Respondent's determination that petitioner is liable for a                          
            $16,842 deficiency is presumed correct, and petitioner bears the                          
            burden of proving it erroneous.  Rule 142(a); Welch v. Helvering,                         
            290 U.S. 111, 115 (1933).  Petitioner conceded that he received                           
            wages, but contended that his "hard work [did not] [constitute]                           
            * * * taxable income."  Petitioner's contention is groundless.                            
            Accordingly, we reject it and hold that petitioner is liable for                          
            the deficiency.                                                                           
                  Respondent also determined that petitioner, pursuant to                             
            section 6654, is liable for an addition to tax for failing to                             
            make estimated tax payments.  Petitioner has the burden of                                
            proving that respondent's determination is erroneous.  Rule                               
            142(a); Baldwin v. Commissioner, 84 T.C. 859, 871 (1985).                                 
            Petitioner did not offer any evidence relating to this issue.                             
            Therefore, we hold that petitioner is liable for the section 6654                         
            addition to tax.                                                                          
                  Respondent also determined that petitioner, pursuant to                             
            section 6651, is liable for an addition to tax for failing to                             
            file a tax return in a timely manner.  In response, petitioner                            




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