-30-
estimated tax for taxable year 2000, we find that respondent has
satisfied respondent's burden of production with respect to the
addition to tax under section 6654(a) for that year. In that
event, we further find on the instant record (1) that none of the
exceptions in section 6654(e) applies13 and (2) that petitioner
is liable for the addition to tax under section 6654(a) for
taxable year 2000.
In the event that the calculation relating to section 6654
were to establish that petitioner did not underpay his estimated
tax for taxable year 2000, we find that respondent has not
satisfied respondent's burden of production with respect to the
addition to tax under section 6654(a) for that year and that
petitioner is not liable for such addition to tax.
We have considered all of the contentions and arguments of
petitioner that are not discussed herein, and we find them to be
without merit, irrelevant, and/or moot.
To reflect the foregoing and the concessions of the parties,
Decision will be entered
under Rule 155.
13Petitioner does not take the position that one or more of
the exceptions in sec. 6654(e) apply in the instant case.
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