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examination, we further find that petitioner has failed to carry
his burden of demonstrating error in respondent’s determination
that he is liable for taxable year 2000 for the addition to tax
under section 6651(a)(1).
We turn finally to whether petitioner is liable for the
addition to tax under section 6654(a). Section 6654(a) imposes
an addition to tax in the case of an underpayment of estimated
tax by an individual.
Respondent has the burden of production with respect to the
addition to tax under section 6654(a).12 Sec. 7491(c); Higbee v.
Commissioner, supra at 446-447. We find that the record contains
evidence from which the parties, in the computations under Rule
155, will be able to calculate the amount of any required in-
stallment by petitioner within the meaning of section 6654(d)(1)
with respect to taxable year 2000 and the amount, if any, of an
underpayment of estimated tax for that year. In the event that
such calculation were to establish that petitioner underpaid his
12For purposes of sec. 6654(a), it is necessary to determine
whether there is an underpayment of a required installment of
estimated tax. See sec. 6654(a) and (b). In this connection,
the amount of any required installment is 25 percent of the
required annual payment. Sec. 6654(d)(1)(A). The required
annual payment is equal to the lesser of (1) 90 percent of the
tax shown in the return for the taxable year or, if no return was
filed, 90 percent of the tax for such year, or (2) if the indi-
vidual filed a return for the preceding taxable year, 100 percent
of the tax shown in such return. Sec. 6654(d)(1)(B). We have
found that petitioner did not file a return for 2000, the taxable
year at issue, or for 1999, the preceding taxable year.
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