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abated with respect to the audit years preclude him from
prevailing with respect to the deficiencies and additions to tax
remaining at issue, (2) amounts petitioner remitted at the time
of filing extension requests for 1996 and 1997 reduce the
deficiencies determined for those years, and (3) respondent has
satisfied his burden of production under section 7491(c) with
respect to the section 6654(a) additions to tax remaining at
issue.
Unless otherwise noted, all section references are to the
Internal Revenue Code in effect for the years at issue, and all
Rule references are to the Tax Court Rules of Practice and
Procedure.
Background
The parties have filed a stipulation of facts and have
submitted this case without trial pursuant to Rule 122. The
stipulation of facts, with accompanying exhibits, is incorporated
herein by this reference. We have inferred additional facts from
uncontested portions of the parties’ submissions. We shall set
forth only such facts as are necessary to understand our
discussion and conclusion.
At the time he filed the petition, petitioner resided in
Arlington, Texas.
Although he requested an extension of time to file his
Federal income tax return for each of the audit years, petitioner
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