§6554

Respondent satisfied the burden ofproduction for the section 6554 addition to tax with respect to tax year 2002.

The amount ofan underpayment under section 6554(a) is the excess ofthe required installment ofestimated tax over the amount ofthe installment paid on or before the due date ofthe installment.

sustain respondent’s assertion of section 6654 additions to tax as set forth in the 9 On brief, petitioner suggests, with little elaboration and without reference to any supporting facts in the record, that he might qualify for the exceptions under sec. 6554(e)(1), involving situations where the tax amount is small (generally $500 ($1,000 for tax years beginning after Dec. 31, 1997), after taking into account the sec. 31 credit for taxes withheld on wages), and sec. 6654(e)(2), involving situat

FACT AND OPINION WHALEN, Judge: Respondent determined the following deficiencies in, additions to, and penalty with respect to petitioner's Federal income tax for 1990, 1991, and 1993: - 2 - Penalty and Addition to Tax Year Deficiency Sec. 6651(a) Sec. 6554 Sec. 6662(a) 1990 $2,284 $571 $150 -0- 1991 2,374 -0- –0- $475 1993 24,654 6,164 1,035 –0- After concessions, the issues for decision are: (1) Whether petitioner is entitled to deduct wagering losses in the amount of $19,690 for the taxable y