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establish reasonable cause for failure to file a timely tax
return. See Elec. & Neon, Inc. v. Commissioner, 56 T.C. 1324,
1342-1343, (1971), affd. without published opinion 496 F.2d 876
(5th Cir. 1974). A taxpayer is required to file timely based
upon the best information available and to file thereafter an
amended return if necessary. Estate of Vriniotis v.
Commissioner, 79 T.C. 298, 311 (1982).
Petitioner has not established that her failure to timely
file for 2000 was due to reasonable cause. See Higbee v.
Commissioner, supra at 446-447. Accordingly, petitioner is
liable for the section 6651(a)(1) addition to tax for 2000.
C. Section 6654(a)
Respondent determined that petitioner is liable for an
addition to tax pursuant to section 6654(a) for 2000. Section
6654(a) imposes an addition to tax for failure to pay estimated
income tax. The amount of the credit for withholding is deemed
to be a payment of estimated tax. See sec. 6654(g).
Petitioner’s Form W-2, Wage and Tax Statement, indicates that
petitioner had $1,235 withheld for her 2000 tax year. Petitioner
stipulated that she did not make any estimated income tax
payments for 2000. We have found for respondent on the issue of
petitioner’s claimed deductions for the year 2000.
We conclude that respondent has satisfied his burden of
production regarding this issue. Petitioner has failed to come
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