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that the taxpayer bears the burden of proof regarding reasonable
cause). Accordingly, on this issue, we sustain respondent’s
determination.
2. Section 6651(a)(2). Failure To Pay
Section 6651(a)(2) provides for an addition to tax where
payment of tax is not timely “unless it is shown that such
failure is due to reasonable cause and not due to willful
neglect”. Under penalty of perjury, Revenue Agent Laakso swore
that respondent’s records reflect that petitioner failed to pay
income taxes for the years in issue.
Based upon the evidence, we find as a fact that petitioner
did not pay his taxes for the years in issue. Petitioner did not
present evidence indicating that his failure to pay was due to
reasonable cause and not due to willful neglect. See Higbee v.
Commissioner, supra at 446-447 (stating that the taxpayer bears
the burden of proof regarding reasonable cause). Accordingly, on
this issue, we sustain respondent’s determination.
3. Section 6654. Failure To Pay Estimated Tax
Section 6654 imposes an addition to tax for failure to pay
estimated income tax. Respondent submitted petitioner’s Forms
W-2 and petitioner’s transcript of account listing Forms 1099B,
1099S, 1099DIV, and 1099INT received by the IRS for 1996 and
1997. The forms indicate that no Federal income tax was
withheld. On the basis of this evidence and the declaration of
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