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Petitioner has not presented any evidence to suggest that his
failure to file was due to reasonable cause. In fact, his sole
argument is a terse assertion that respondent failed to meet the
burden of production. Petitioner is incorrect. Consequently,
the Court sustains respondent’s imposition of an addition to tax
pursuant to section 6651(a)(1).
C. Section 6654(a) Addition to Tax
Section 6654(a) imposes an addition to tax for underpayment
of estimated income tax by an individual taxpayer. That addition
to tax, asserted by respondent only with respect to the 2001
taxable year, is computed by reference to four required
installment payments of the taxpayer’s estimated tax liability,
each constituting 25 percent of the “required annual payment.”
Sec. 6654(d)(1)(A). For taxpayers whose adjusted gross income
for the preceding year was $150,000 or less, the “required annual
payment” is equal to the lesser of (1) 90 percent of the tax
shown on the individual's return for the year or, if no return is
filed, 90 percent of his or her tax for such year, or (2) if the
individual filed a return for the immediately preceding taxable
year, 100 percent of the tax shown on that return. Sec.
6654(d)(1)(A), (B)(i) and (ii).
Here, petitioner failed to file a 2001 Federal income tax
return and made no estimated tax payments for 2001. Petitioner
also failed to file a 2000 Federal income tax return. Because
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