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received by respondent until November 5, 2002. Accordingly, we
conclude that respondent has met his burden of production under
section 7491(c) regarding petitioner's liability for the addition
to tax under section 6654.
Respondent having met his burden of production, it is
incumbent upon petitioner to show that he is eligible for one of
the statutorily provided exceptions to the section 6654 addition
to tax. See sec. 6654(e); Higbee v. Commissioner, supra at 446.
Petitioner testified that he became disabled because of a
detached retina in 1998 and continued to be disabled through the
time of trial. While section 6654(e)(3)(B) provides for a waiver
of the addition where the Secretary determines that a taxpayer
became disabled in the year for which the estimated taxes were
required or the preceding year, such a waiver also requires that
the underpayment of estimated tax be due to reasonable cause.
Sec. 6654(e)(3)(B)(ii). Thus, even had petitioner become
disabled during 1999 or 2000, section 6654(e)(3)(B) would provide
him no relief, since we have previously concluded that the
circumstances surrounding petitioner's failure to remit the June
2000 estimated tax payment do not constitute reasonable cause.
As petitioner has neither claimed nor shown entitlement to
any other exception, we hold that he is liable for an addition to
tax under section 6654 for 2000.
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