- 18 -
6651(a)(1). On that record, we further find that petitioner has
failed to carry her burden of showing that her failure to file a
tax return for 2000 was due to reasonable cause, and not due to
willful neglect.
Respondent conceded in the answer the addition to tax under
section 6651(a)(2) determined in the notice. As a result,
according to respondent, section 6651(c)(1) does not apply. We
agree with respondent. On the record before us, we find that
respondent has established that the amount of the addition to tax
under section 6651(a)(1) that respondent determined in the notice
should be increased.8
Addition to Tax Under Section 6654(a)
Respondent determined that petitioner is liable for the
addition to tax under section 6654(a). Section 6654(a) imposes
an addition to tax in the case of an underpayment of estimated
tax by an individual.9
8The increase in the addition to tax under 6651(a)(1) that
we have sustained will be determined by the parties under Rule
155.
9For purposes of sec. 6654(a), it is necessary to determine
whether there is an underpayment of a required installment of
estimated tax. See sec. 6654(a) and (b). In this connection,
the amount of any required installment is 25 percent of the
required annual payment. Sec. 6654(d)(1)(A). The required
annual payment is equal to the lesser of (1) 90 percent of the
tax shown in the tax return for the taxable year or, if no tax
return was filed, 90 percent of the tax for such year, or (2) if
the individual filed a tax return for the preceding taxable year,
100 percent of the tax shown in such return. Sec. 6654(d)(1)(B).
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