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taxable year, 100 percent of the tax shown on that return.6 Sec.
6654(d)(1)(A), (B), and (C). A taxpayer has an obligation to pay
estimated tax for a particular year only if he has a “required
annual payment” for that year. Sec. 6654(d); Wheeler v.
Commissioner, 127 T.C. ___, ___ (2006) (slip op. at 20-21).
To satisfy his burden of production, respondent introduced
evidence establishing that 90 percent of petitioner’s $86,858
income tax liability for 2000 was $78,172, that petitioner had
withholding tax credits of $14,628 for 2000, that petitioner made
no estimated tax payments for 2000, and that petitioner had filed
a Federal income tax return for 1999 showing a Federal income tax
liability of $52,589. This evidence is sufficient to satisfy
respondent’s initial burden of providing evidence that petitioner
had a required annual payment for 2000 payable in installments
under section 6654 and that petitioner underpaid his estimated
tax liability for 2000. Petitioner offered no evidence
whatsoever to refute respondent’s evidence or to establish a
defense to respondent’s determination that petitioner is liable
for the section 6654 addition to tax. Consequently, we conclude
that respondent’s determination that petitioner is liable for the
section 6654 addition to tax must be sustained.
6If an individual’s adjusted gross income shown on the
previous year’s return exceeds $150,000, a higher percentage may
apply. See sec. 6654(d)(1)(C).
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Last modified: May 25, 2011