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determination as to the addition to tax under section 6651(a)(1)
included in the notice, but we hold for petitioner as to the
portion of that addition to tax asserted in the answer.
B. Section 6654(a)
Section 6654 provides for an addition to tax in the event of
an underpayment of a required installment of individual estimated
tax. Sec. 6654(a) and (b). Petitioner has assigned error to
respondent’s determination of a section 6654(a) addition to tax,
but he did not in the petition set forth any facts in support of
that assignment. The Nov. 10 return does show $7,940 as the sum
of (1) 2000 estimated tax payments and (2) the amount applied
from petitioner’s 1999 return. Petitioner has offered nothing to
corroborate that he made any estimated tax payment for 2000 or
that any amount was applied from his 1999 return. Indeed,
respondent introduced into evidence a transcript of petitioner’s
accounts for both 1999 and 2000 that, among other things, shows
no return filed for 1999 and no payments or credits made during
2000. Without corroboration, we need not accept that petitioner
paid any estimated tax. See Wilkinson v. Commissioner, 71 T.C.
at 639. Moreover, on brief, petitioner fails to address the
section 6654 addition (although he does address the section
6651(a)(1) addition to tax). Because of that failure, we assume
that petitioner has abandoned any claim that a section 6654(a)
addition to tax is unwarranted. See Greene-Thapedi v.
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