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sale of the arcade games.18
Addition to Tax Under Section 6651(a)(1)
Respondent determined that petitioner is liable for 1996 for
an addition to tax under section 6651(a)(1). The record estab-
lishes that petitioner did not file a tax return for 1996.
Petitioner claims that he does not have the requisite amount of
income that would have required him to file a tax return for that
year. The record in the instant case belies that claim. In a
stipulation of settled issues filed by the parties on April 16,
2002, petitioner conceded that for 1996 he has $6,178 of income,
consisting of $4,000 of income with respect to his employment by
Uptime Nutrition and $2,178 of income with respect to unemploy-
ment compensation from the Minnesota Department of Economic
Security. Based on petitioner’s concessions alone, he was
required to file a tax return for 1996.19 See sec. 6012. On the
record before us, we find that petitioner has failed to carry his
burden of showing that he is not liable for an addition to tax
under section 6651(a)(1) for 1996.
We have considered all of the contentions and arguments of
petitioner that are not discussed herein, and we find them to be
18Petitioner does not contend, and has failed to establish,
that he has a basis in the arcade games that he sold to Reality
Entertainment.
19In addition to the $6,178 of income that petitioner con-
ceded he has for 1996, we have found that petitioner has
$115,836.61 of income for that year.
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