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computational adjustment only and no new issue is raised by the
amended answer. We shall therefore grant respondent's motion to
amend.
All of the material allegations set forth in the petition in
support of assignments of error were denied in respondent's
answer. Accordingly, the burden of proof rests with petitioner
concerning any error in the deficiency respondent determined for
the 2002 taxable year, and petitioner has adduced no evidence in
support of the assignments of error made in the petition.
In his amended answer, respondent asserted additions to tax
under sections 6651(a)(1) and 6654(a) for which, pursuant to
section 7491(c), respondent generally bears the burden of
production to show that imposition of the additions to tax is
appropriate. See Higbee v. Commissioner, 116 T.C. 438, 446
(2001). Rule 34(b)(4) provides that a petition in a deficiency
action shall contain clear and concise assignments of "each and
every error" in the Commissioner's determination as well as
statements of the facts upon which the taxpayer bases the
assignments of error. Where the taxpayer has not made the
foregoing specific allegations, the Commissioner incurs no burden
of production with respect to the additions to tax that have been
determined. Funk v. Commissioner, 123 T.C. 213, 215 (2004).
The petition in this case does not contain any specific
allegations regarding the additions to tax or of facts to support
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