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of $30,887. On the record before us, we find that petitioner has
failed to carry his burden of establishing that he is entitled to
deductions for the taxable years at issue in excess of those
allowed in the respective notices of deficiency that respondent
issued for those years. On that record, we sustain respondent’s
deficiency determination for each of those years.
With respect to respondent’s respective determinations for
the years at issue of additions to tax under section 6651(a)(1),
petitioner made the following allegations in the petition with
respect to his failure to file a tax return for either of those
years:
There was no return due for both years in ques-
tion, thus no return for the periods here involved was
filed with the Office of the Internal Revenue Service
nor has any person been authorized by the Petitioner to
file such non required returns. Any claims to the
contrary would be fraudulent.
The record establishes, and petitioner concedes in the
petition, that he did not file a tax return for either of the
years at issue. The record establishes that petitioner received
wage income of $15,406 and unemployment compensation of $9,375
for his taxable year 1998 and wage income of $30,887 for his
taxable year 2001. On the record before us, we find that respon-
dent has satisfied respondent’s burden of production with respect
to the addition to tax under section 6651(a)(1) that respondent
determined for each of the years at issue. See sec. 7491(c);
Higbee v. Commissioner, 116 T.C. 438, 446 (2001). On that
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