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With respect to the section 6651(a)(1) addition to tax for
failure to file timely, we find that respondent has satisfied his
burden of production. Respondent adduced a certified transcript
of account for petitioner's 2001 taxable year, which shows that
petitioner failed to file a return for that year. An information
return, corroborated by Mr. Meadows's testimony, indicates
petitioner received income of $56,718.99 in 2001, an amount that
is sufficient to impose a return-filing obligation on petitioner.
Sec. 6012. Petitioner has offered no evidence of reasonable
cause or any other basis on which she would not be liable for the
section 6651(a)(1) addition to tax. See Higbee v. Commissioner,
supra.
Respondent has also met his burden of production with
respect to the section 6654 addition to tax for failure to pay
estimated taxes. Petitioner's income tax deficiency for 2001 is
sufficient to obligate her to make estimated tax payments. A
certified transcript of account for petitioner's 2000 taxable
year indicates that she also failed to file a return in that
year. The certified transcript of account for 2001 indicates
that petitioner had no withholding, made no estimated tax
payments, and had no other credits or payments for 2001. The
foregoing is sufficient evidence to satisfy respondent's burden
of production under section 7491(c) with respect to the section
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Last modified: November 10, 2007