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Contrary to his assertions, petitioner was required to file
Federal income tax returns for each of the years in issue because
his income exceeded the maximum amount exempt from filing in each
of the taxable years. Secs. 6012, 6072. Petitioner offered no
evidence that his failure to timely file was due to reasonable
cause and not due to willful neglect. We conclude that
petitioner is liable for an addition to tax pursuant to section
6651(a)(1).
Section 6654 imposes an addition to tax for failure to pay
estimated income tax. Forms 4340, Certificate of Assessments,
Payments, and Other Specified Matters, Forms W-2, Forms 1099, and
the testimony of petitioner’s employers establish that petitioner
failed to pay the required estimated tax for 1998, 1999, and
2000. We conclude that respondent satisfied his burden of
production regarding this issue.
Petitioner presented no evidence that he is not liable for
this addition to tax for any of the years in issue. Accordingly,
we hold that petitioner is liable for the addition to tax
pursuant to section 6654(a).
D. Penalty Pursuant to Section 6673(a)
Respondent filed a motion asking the Court to impose a
penalty pursuant to section 6673(a). Section 6673(a)(1)
authorizes this Court to require a taxpayer to pay to the United
States a penalty not to exceed $25,000 if the taxpayer took
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