- 19 - Respondent introduced evidence to prove petitioner was required to file a Federal income tax return for 2000, did not file a Federal income tax return for 2000, and failed to make any estimated tax payments for 2000. However, in order to permit this Court to make the analysis required by section 6654(d)(1)(B)(ii) and to conclude respondent met his burden of producing evidence that petitioner had a required annual payment for 2000 payable in installments under section 6654, respondent also must introduce evidence showing whether petitioner filed a return for the preceding taxable year, and, if so, the amount of tax shown on that return. See Wheeler v. Commissioner, supra at 212. The parties stipulated petitioner’s 1999 Federal income tax return, which reported a tax liability of $11,155. See Mendes v. Commissioner, 121 T.C. 308, 324 (2003). Even though petitioner’s return was untimely filed on September 15, 2004, and was filed during respondent’s examination of his 1999 tax year, it was filed before the notice of deficiency was issued. Therefore, the Court finds that $11,155 is the amount to compute the required annual payment under section 6654(d)(1)(B)(ii). See Mendes v. Commissioner, supra at 324-325. The Court concludes respondent met his burden of production. Petitioner did not dispute that he failed to make estimated tax payments for 2000 or assert that he fell within any statutory exception under section 6654. See sec. 6654(e). Consequently,Page: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 NextLast modified: November 10, 2007