Rita Grant Ndirika - Page 19

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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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