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extension of time for filing), unless such failure is due to
reasonable cause and not due to willful neglect.
Respondent submitted a certified transcript of petitioner’s
account for 1997. The certified transcript states that
petitioner did not file a return for 1997. Accordingly,
respondent has met his burden of production for the section
6651(a)(1) addition to tax for 1997.
Petitioner has not established that his failure to timely
file for 1997 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 1997.
c. Section 6654(a)
Section 6654 imposes an addition to tax for failure to pay
estimated income tax. Respondent submitted petitioner’s Form W-2
for 1997 from Enterprise Network Sys., Inc., and a certified
transcript of petitioner’s account for 1997. The forms indicate
that petitioner did not have any Federal income tax withheld and
did not make any estimated income tax payments for 1997. We
conclude that respondent has satisfied his burden of production
regarding this issue. Thus, petitioner must come forward with
evidence sufficient to persuade the Court that respondent’s
determination is incorrect. See Rule 142(a); Welch v. Helvering,
290 U.S. 111, 115 (1933); see Higbee v. Commissioner, supra at
447.
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