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and the testimony of the revenue agent who audited petitioner,
both to the effect that respondent’s records do not indicate that
respondent has ever received a Federal income tax return from
petitioner for the subject year. Petitioner, in turn, has failed
to meet his burden of proof. Petitioner has never presented any
credible evidence indicating that he filed a 1997 tax return, nor
has he established that his failure to file the return was on
account of cause that is reasonable. We hold that petitioner is
liable for the addition to tax under section 6651(a)(1). See
United States v. Boyle, 469 U.S. 241, 245 (1985); Cluck v.
Commissioner, 105 T.C. 324, 338-339 (1995).
2. Section 6654(a)
Section 6654 imposes an addition to tax on an underpayment
of estimated tax. This addition to tax is mandatory unless the
taxpayer establishes that one of the exceptions listed in section
6654(e) applies. Recklitis v. Commissioner, 91 T.C. 874, 913
(1988).
The record establishes that petitioner failed to pay the
required amount of estimated tax for 1997. We conclude that
respondent has met his burden of production as to this issue.
Given that the record does not establish that any of the
referenced exceptions applies, we conclude that petitioner has
failed to meet his burden of proof and sustain respondent’s
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