Gloria J. Spurlock - Page 29

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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           

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