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respondent has met his burden of production with regard to the
addition to tax under section 6651(a)(1).
Petitioner has presented no evidence indicating his failure
to file was due to reasonable cause or that respondent’s
determination is otherwise incorrect. We hold that petitioner is
liable for an addition to tax under section 6651(a)(1) of $3,225.
3. Section 6654(a)
Respondent determined that petitioner is liable for an
addition to tax under section 6654(a) of $431 for 2002. Section
6654(a) imposes an addition to tax on an underpayment of
estimated tax unless one of the statutory exceptions applies.
See sec. 6654(e). Under Rule 91(f), it was deemed stipulated
that petitioner failed to file a Federal income tax return for
2002 and did not make estimated tax payments during 2002.
Respondent’s Certificate of Assessments and Payments also
indicates that petitioner failed to file a return and did not
make estimated tax payments. We find that none of the statutory
exceptions applies and that respondent has met his burden of
production.
Petitioner has presented no evidence that respondent’s
determination is incorrect. We hold that petitioner is liable
for an addition to tax under section 6654(a) of $431.
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Last modified: May 25, 2011