- 29 - 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...)Page: Previous 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 Next
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