- 22 -
Based on the foregoing, we conclude that respondent
established a prima facie case that the determination of 25-
percent additions to tax under section 6651(a)(1) with respect to
Dr. Trowbridge for the years 1994 and 1995, and with respect to
Ms. Martin for the years 1991-95, is appropriate, thereby
satisfying section 7491(c). In the absence of any evidence
refuting that prima facie case (such as reasonable cause or lack
of willful neglect on the part of either petitioner), we conclude
that petitioners are liable for such additions to tax. Except as
noted below,12 we also accept respondent’s computation of the
amounts of those additions as set forth in the notices of
deficiency.
3. Respondent’s Section 6654 Determinations
As relevant to his section 6654 determinations, respondent
introduced into evidence Dr. Trowbridge’s invalid return for 1993
in addition to the evidence of invalid and nonexistent returns
discussed above in the context of his section 6651(a)(1)
determinations. Respondent also produced evidence that, aside
11(...continued)
property State). Respondent also properly credited Ms. Martin
with her earned income credit for 1995. See sec. 6651(b)(1).
12 Respondent inexplicably based his 1992 sec. 6651(a)(1)
computation for Ms. Martin on tax of $8,764 rather than the
$8,740 amount of tax that appears elsewhere in the notice of
deficiency issued to her. The correct amount of such addition
shall be the subject of a Rule 155 computation.
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