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indeed, the date entries span several years. The half-page
printouts are dated November 22, 2000. Those printouts contain
the notation “Received-Date: 10071999”. Each of the Forms 1040
is dated September 23, 1999. The computer-generated Forms
5344(CG) contain no date. The manually completed Forms 5344 are
dated May 31, 2001. The Form 4549-CG contains income tax
examination changes for 1995, 1996, and 1997. Page 1 of that
form contains no date. Page 2 of that form is dated October 18,
1999. The pages attached to that form, which contain
computations relating to the income tax examination changes, are
also dated October 18, 1999. The 30-day letter is dated October
18, 1999. We cannot agree that this conglomeration of documents,
which appears to be respondent’s administrative file, would
satisfy the requirements of section 6020(b) even if it were in
evidence. See Cabirac v. Commissioner, supra.
Section 6654(a) provides for an addition to tax in the case
of an underpayment of estimated tax. We find that respondent has
satisfied his burden of production with respect to the addition
to tax under section 6654(a) for each of the tax years at issue.
Petitioner did not file Federal income tax returns for 1995,
1996, and 1997, and she did not pay taxes on income other than
those amounts the various payors withheld.21 Further, respondent
21The Forms W-2 that Ursuline prepared show Federal income
tax withheld of $582.78 for 1995 and $751.29 for 1997. The Forms
(continued...)
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