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return for 2000 and is liable for the addition to tax under
section 6651(a)(1) of $6,322 for 2000.
3. Whether Petitioner Is Liable for the Addition to Tax
Under Section 6654 for Failure To Pay Estimated Tax
Respondent has met the burden of production under section
7491(c) with respect to the addition to tax for failure to pay
estimated tax under section 6654(a) because the record shows that
petitioner did not pay estimated tax with respect to his tax
liability for 2000.
Petitioner contends that he is not liable for the addition
to tax under section 6654 for 2000 because no tax was due. We
disagree because (a) tax was due from petitioner for 2000 as
discussed above at paragraph A of the opinion, and (b) section
6654(a) applies for reasons described next.
Section 6654(a) imposes an addition to tax for failure to
pay estimated income taxes unless one of the exceptions in
section 6654(e) applies. Niedringhaus v. Commissioner, 99 T.C.
202, 222 (1992); Grosshandler v. Commissioner, 75 T.C. 1, 20-21
(1980). Petitioner does not allege, and we do not find, that he
paid estimated tax or that any of the exceptions apply. Thus, we
sustain respondent’s determination that petitioner is liable for
the addition to tax under section 6654(a).
E. Petitioner’s Motions To Reopen the Record
Petitioner requests that we reopen the record to admit into
evidence affidavits from Dunstan and his therapist. He contends
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