Kenneth E. Gilmore - Page 17

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          and has not shown that any of the statutory exceptions are                  
          applicable.11  Respondent’s determination as to the addition to             
          tax under section 6654(a) is sustained.                                     
               Reviewed and adopted as the report of the Small Tax Case               
          Division.                                                                   
               To reflect the foregoing,                                              
                                             Decision will be entered                 
                                        under Rule 155.                               


























               11  The burden remains upon petitioner to establish the                
          applicability of any exceptions.  Higbee v. Commissioner, supra             
          at 446; Spurlock v. Commissioner, T.C. Memo. 2003-248.                      




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