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Mr. Rinn’s income from his dental practice. Petitioners
introduced no evidence establishing reasonable cause for their
failures to file; indeed, the record demonstrates that their
failures to file were attributable to their taking frivolous
positions regarding their obligation to report and pay Federal
income taxes. We hold that respondent has met his burden of
production, and we sustain the imposition of section 6651(a)(1)
additions to tax for petitioners’ 1995 through 2000 tax years.14
B. Section 6654 Additions to Tax
Section 6654 provides for an addition to tax in the case of
any underpayment of estimated tax by an individual. Except in
very limited circumstances not applicable in this case, see sec.
6654(e)(3)(B), section 6654 provides no exception for reasonable
cause, Mendes v. Commissioner, 121 T.C. 308, 323 (2003).
Instead, the section 6654 addition to tax is mandatory unless one
of the limited statutory exceptions applies. Sec. 6654(e);
Recklitis v. Commissioner, 91 T.C. 874, 913 (1988).
We conclude that respondent has met his burden of production
under section 6654. It is clear from the record that petitioners
14 In the Rule 155 computation, we anticipate that the
parties will make appropriate adjustments to the sec. 6651(a)(1)
additions to tax to account for respondent’s concessions,
including respondent’s concession that Mr. and Mrs. Rinn should
be treated as married persons filing separate returns, with no
double counting in Mr. Rinn’s taxable income of community-
property items included in the computation of Mrs. Rinn’s taxable
income, and respondent’s concessions of the sec. 6651(a)(2)
additions to tax. See sec. 6651(c)(1).
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