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Petitioner alleged in the petition that he is entitled to
claim deductions. However, petitioner has not identified the
items that he contends are deductible or offered any evidence
supporting his claim. Thus, he may not deduct any amount for
2000 or 2002.
We conclude that petitioner’s deficiencies in income tax
were $5,457 for 2000 and $9,164 for 2002.
D. Additions to Tax
Section 7491(c) places on the Commissioner the burden of
producing evidence that it is appropriate to impose additions to
tax. To meet the burden of production under section 7491(c), the
Commissioner must produce evidence showing that it is appropriate
to impose the particular addition to tax but need not produce
evidence relating to defenses such as reasonable cause or
substantial authority. Higbee v. Commissioner, 116 T.C. 438, 446
(2001); H. Conf. Rept. 105-599, supra at 241, 1998-3 C.B. at 995.
Respondent has met the burden of production under section
7491(c) with respect to the addition to tax for failure (a) to
file under section 6651(a)(1) because the record shows that
petitioner is required to but has not filed a return for 2000 and
2002; and (b) to make estimated tax payments under section
6654(a) because the record shows that petitioner did not make
estimated tax payments, except for nominal amounts withheld from
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