- 5 - method of accounting requiring him to report the $12,000 in a period other than the period ending December 31, 2002. Accordingly, the Court holds that petitioner was required to report the $12,000 in 2002. Respondent determined that petitioner is liable for additions to tax under sections 6651(a)(1) and 6654(a). Respondent bears the burden of production with respect to petitioner’s liability for the additions to tax. Sec. 7491(c); Higbee v. Commissioner, 116 T.C. 438, 446-447 (2001). To meet his burden of production, respondent must come forward with sufficient evidence indicating it is appropriate to impose the additions to tax. Higbee v. Commissioner, supra at 446-447. Section 6651(a)(1) imposes an addition to tax for failure to file a return on the date prescribed (determined with regard to any extension of time for filing), unless the taxpayer can establish that such failure was due to reasonable cause and not willful neglect. The parties stipulated that petitioner did not timely file the 2002 return. Respondent has met his burden of production. Petitioner did not show reasonable cause for failing to timely file a return for 2002. Sec. 6651(a)(1). Therefore, the Court holds that petitioner is liable for the section 6651(a)(1) addition to tax for 2002. Section 6654(a) imposes an addition to tax on an individual taxpayer who underpays his estimated tax. The addition to taxPage: Previous 1 2 3 4 5 6 7 8 NextLast modified: March 27, 2008