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sufficient to persuade the Court that respondent’s determination
is incorrect or that an exception applies. Rule 142(a); Welch v.
Helvering, 290 U.S. at 115; see Higbee v. Commissioner, supra at
447.
Petitioner presented no evidence that he timely filed a
return for 1999 or that his failure to file was due to reasonable
cause and not due to willful neglect. We hold that petitioner is
liable for the addition to tax pursuant to section 6651(a)(1).
B. Section 6654(a)
Section 6654 imposes an addition to tax for failure to pay
estimated income tax. Respondent submitted petitioner’s Form W-
2, Wage and Tax Statement, for 1999 from Kmart and a Form 4340,
Certificate of Assessments, Payments, and Other Specified
Matters, for petitioner’s 1999 tax year. The forms indicate that
petitioner did not have any Federal income tax withheld and did
not make any estimated income tax payments for 1999. We conclude
that respondent satisfied his burden of production regarding this
issue. Thus, petitioner must come forward with evidence
sufficient to persuade the Court that respondent’s determination
is incorrect or that an exception applies. Rule 142(a); Welch v.
Helvering, supra at 115; see Higbee v. Commissioner, supra at
447.
Petitioner presented no evidence that he had any income tax
withheld, paid any estimated income taxes for 1999, or that an
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