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We have jurisdiction in this case to redetermine
petitioner’s deficiency for 2000. We may consider facts from
other years if necessary to redetermine the deficiency for 2000.
Sec. 6214(b). We need not review respondent’s application of
petitioner’s overpayment for 1992 to 1979 to redetermine
petitioner’s tax liability for 2000. Thus, we lack jurisdiction
to decide this issue.
D. Whether Petitioner Is Liable for the Addition to Tax Under
Section 6651(a)(1) in an Amount More Than Respondent
Determined
1. Burden of Production
An unmarried individual (who is not a surviving spouse or
head of household) must file an income tax return if his or her
gross income for the year equals or exceeds the exemption amount
plus the basic standard deduction for that individual. Sec.
6012(a)(1)(A)(i).
Section 7491(c) places on the Commissioner the burden of
producing evidence that it is appropriate to impose additions to
tax. To meet that burden, 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,
at 241 (1998), 1998-3 C.B. 747, 995. Once the Commissioner meets
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