Harold A. Lange - Page 21

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               We have sustained respondent's determinations that                     
          petitioner had gross income of $46,306 in 2000.  Petitioner                 
          admitted on the 2000 Form 1040 that no estimated taxes were paid            
          nor was any tax withheld with respect to 2000.  The information             
          returns of NEBF, EWTF, and the Kentucky Lottery Corporation                 
          likewise corroborate that no tax was withheld with respect to               
          petitioner's pension disbursements and lottery winnings.  We                
          accordingly conclude that respondent has met his burden of                  
          production with respect to the section 6654 addition.  As                   
          petitioner's only argument is that "there is no longer                      
          legislation which authorizes" the section 6654 addition to tax,             
          we sustain respondent's determination.                                      
          VI. Conclusion                                                              
               We have considered all remaining arguments made by the                 
          parties for contrary holdings and, to the extent not addressed,             
          find them to be irrelevant, moot, or meritless.                             
               To reflect the foregoing,                                              

                                             Decision will be entered                 
                                        under Rule 155.                               













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