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notice of deficiency and did not otherwise have an opportunity to
dispute those additions to tax. We shall review on a de novo
basis respondent’s determinations with respect to such increases
in the 1999 additions to tax. Sego v. Commissioner, supra; Goza
v. Commissioner, supra. Section 6651(a)(1) imposes an addition
to tax for failure to file timely a return. Section 6651(a)(2)
imposes an addition to tax for failure to pay timely the amount
shown as tax in a return. The respective additions to tax under
section 6651(a)(1) and (2) do not apply if the failures to file
timely and to pay timely are due to reasonable cause and not to
willful neglect. Respondent has the burden of production with
respect to the increases in the 1999 additions to tax under
section 6651(a)(1) and (2). Sec. 7491(c); Higbee v. Commis-
sioner, 116 T.C. 438, 446 (2001). Although respondent bears the
burden of production with respect to such increases, respondent
“need not introduce evidence regarding reasonable cause * * * or
similar provisions. * * * the taxpayer bears the burden of proof
with regard to those issues.” Higbee v. Commissioner, supra.
With respect to the increase in the 1999 addition to tax
under section 6651(a)(1), petitioner claims, and respondent
disputes, that petitioner submitted timely an unsigned return for
his taxable year 1999. Assuming arguendo that petitioner had
timely submitted an unsigned return for his taxable year 1999,
such unsigned return does not constitute a valid tax return for
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