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Petitioner did not file a return for 1997. Petitioner made
no showing that his failure to file was due to reasonable cause
and not willful neglect. Respondent’s determination in regard to
the section 6651(a)(1) addition to tax is sustained.
2. Section 6654(a)
Section 6654(a) provides for an addition to tax in the case
of an underpayment of estimated tax. Once the Commissioner meets
his initial burden of production to show that the addition to tax
is appropriate, the section 6654(a) addition to tax is mandatory
unless petitioner shows that one of the statutorily provided
exceptions applies. See sec. 6654(e); Higbee v. Commissioner,
supra at 447; Grosshandler v. Commissioner, 75 T.C. 1, 20-21
(1980).
As relevant to this discussion, section 6654(e) provides two
mechanical exceptions to the applicability of the section 6654
addition to tax. First, the addition is not applicable if the
tax shown on the taxpayer’s return for the year in question (or,
if no return is filed, the taxpayer’s tax for that year), reduced
by any allowable credit for wage withholding, is less than $500.
Sec. 6654(e)(1). Second, the addition to tax is not applicable
if the taxpayer’s tax liability for the preceding taxable year
was zero. Sec. 6654(e)(2).
Petitioner did not file a 1997 return, did not have Federal
income taxes withheld from his wages, and made no estimated tax
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