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taxable year 2000.
In the event that the calculation relating to section 6654
were to establish that petitioner did not underpay her estimated
tax for her taxable year 2000, we find that respondent has not
satisfied respondent’s burden of production with respect to the
addition to tax under section 6654(a) for that year and that
petitioner is not liable for such addition to tax.
We have considered all of the contentions and arguments of
petitioner that are not discussed herein, and we find them to be
irrelevant and/or without merit.
To reflect the foregoing and the concessions of the parties,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011