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tively. The Internal Revenue Service (Service) has no record
that petitioner filed her 1989 and 1990 tax returns on those
respective dates or on any other dates. Nor does the Service
have a record that petitioner filed tax returns for 1991, 1992,
and 1993.
Tax was withheld in the amounts of $330 and $58 from the
wages that petitioner received during 1989 and 1993, respec-
tively. No tax was withheld from the $18 of wages that peti-
tioner received during each of the years 1990 and 1991. No tax
was withheld for petitioner’s taxable year 1992 because she
received no wages during that taxable year.
On April 10, 1998, respondent sent petitioner a notice of
deficiency (notice) with respect to her taxable years 1989, 1990,
and 1991 and a separate notice with respect to her taxable years
1992 and 1993. In those notices, respondent determined, inter
alia, that petitioner had failed to file tax returns for the
years at issue, that she is liable for additions to tax under
section 6651(a)(1) for those years, and that she is liable for
additions to tax under section 6654 for her taxable years 1990,
1991, and 1992.
Petitioner bears the burden of showing error in the determi-
nations in the notices. See Rule 142(a); Welch v. Helvering, 290
U.S. 111, 115 (1933). We reject petitioner’s argument that the
standard of proof applicable in criminal proceedings is control-
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