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that he should receive a deduction for only one-half of the
amount of the 2003 liability. Id.
III. Addition to Tax
Respondent determined a section 6651(a)(1) addition to tax
against petitioner. As an initial matter, section 7491(c) places
the burden of production on the Commissioner to show that the
imposition of an addition to tax or a penalty on an individual is
appropriate. To satisfy this burden, respondent must proffer
sufficient evidence indicating that the imposition of the
addition or penalty is appropriate. See Higbee v. Commissioner,
116 T.C. 438, 445 (2001). Respondent satisfied his burden with
respect to the addition to tax by introducing at trial copies of
petitioner’s 1999 Form 1040, third-party information returns
relating to petitioner’s income, and documents containing tax-
protester rhetoric petitioner submitted to the IRS.
Section 6651(a)(1) generally provides that a taxpayer’s
failure to file a timely Federal income tax return, taking into
account extensions, requires the imposition of an addition to
tax, unless the taxpayer shows that such failure was due to
reasonable cause and not due to willful neglect. Petitioner
contends that he is not liable for an addition to tax under
section 6651(a) since he filed a Form 1040. Respondent argues
that petitioner’s Form 1040 does not constitute a valid tax
return for section 6651(a)(1) purposes because it failed to
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