- 7 - payment for 2002 that was payable in installments under section 6654. Therefore, the Court finds respondent failed to meet his burden of production. Accordingly, respondent’s determination regarding the section 6654 addition to tax is not sustained. In reaching these holdings, the Court has considered all arguments made and, to the extent not mentioned, concludes that they are moot, irrelevant, or without merit. To reflect the foregoing, Decision will be entered for respondent as to the deficiency and the addition to tax under section 6651(a)(1), and for petitioner as to the additions to tax under sections 6651(a)(2) and 6654.Page: Previous 1 2 3 4 5 6 7 8Last modified: March 27, 2008