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Respondent has the burden of production with respect to the
addition to tax under section 6654(a). Sec. 7491(c); Higbee v.
Commissioner, supra at 446-447. We have found that petitioner
did not file a tax return for her taxable year 2000 and that
respondent has no record that petitioner filed a tax return for
her taxable year 1999. Petitioner introduced no reliable evi-
dence establishing that she filed a tax return for either of
those years. We have also found that petitioner did not make any
estimated tax payments with respect to her taxable year 2000,
although the amounts of tax withheld during that year are treated
under section 6654(g)(1) as estimated tax payments.
We find that the record contains evidence from which the
parties, in the computations under Rule 155, will be able to
calculate the amount of any required installment by petitioner
within the meaning of section 6654(d)(1) with respect to her
taxable year 2000 and the amount, if any, of an underpayment of
estimated tax for that year. In the event that such calculation
were to establish that petitioner underpaid her estimated tax for
her taxable year 2000, we find that respondent has satisfied
respondent’s burden of production with respect to the addition to
tax under section 6654(a) for that year. In that event, we
further find on the instant record (1) that none of the excep-
tions in section 6654(e) applies and (2) that petitioner is
liable for the addition to tax under section 6654(a) for her
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Last modified: May 25, 2011