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Petitioners received income in the amounts respondent
determined and did not file income tax returns for the years in
issue.5 Petitioners point out that respondent determined that
petitioners are not entitled to deductions for business expenses
to which petitioners claim they are entitled. However,
petitioners offered no evidence contrary to respondent’s
determination.
We conclude that petitioners are each liable for
deficiencies in the amounts that respondent determined for 1994,
1996, and 1997.
B. Additions to Tax
Petitioners admit that they did not file income tax returns
for 1994, 1996, and 1997, and that they received income in those
years in the amounts respondent determined. The parties
stipulated to transcripts of account which show that (1) taxes
were underwithheld from petitioners’ income for 1997 and
(2) petitioners did not pay estimated tax for 1997. Respondent
has met the burden of production under section 7491(c) as to the
additions to tax under section 6651(a) for failure to file for
1994, 1996, and 1997, and under section 6654 for failure to pay
5 Petitioners do not contend and have offered no evidence
showing that sec. 7491(a) applies in this case. Taxpayers bear
the burden of proving that they have met the requirements of sec.
7491(a). H. Conf. Rept. 105-599, at 239 (1998), 1998-3 C.B. 747,
993; S. Rept. 105-174, at 45 (1998), 1998-3 C.B. 537, 581.
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