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and 1997 should be increased.10
With respect to the determinations under section 6654(a),
the matters deemed established show that petitioner did not file
a tax return for any of the years at issue. Those matters also
show that petitioner made an estimated tax payment for each of
the years at issue in an amount significantly less than the
amount of the deficiency in tax that respondent determined, and
that we have sustained, for each such year. On the record before
us, we find that respondent has satisfied respondent’s burden of
production with respect to the addition to tax under section
6654(a) for each of the years at issue. On that record, we
further find that petitioner has failed to establish that any of
the exceptions in section 6654(e) apply in the instant case. On
the record before us, we find that petitioner has failed to carry
his burden of showing that respondent was wrong in determining
that petitioner is liable for each such year for such addition to
tax.
10It appears that respondent may have made an error in
respondent’s amendment to answer in computing the increase in the
addition to tax under sec. 6651(a)(1) for 1997. It appears that
in that computation respondent failed to credit petitioner with
petitioner’s $2,000 estimated tax payment with respect to 1997.
See sec. 6651(b). Any such computational error shall be taken
into account by the parties in the computations under Rule 155.
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Last modified: May 25, 2011