PANUTHOS, Chief Special Trial Judge: This case was heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect at the time the petition was filed. The decision to be entered is not reviewable by any other court, and this opinion should not be cited as authority. Unless otherwise indicated, subsequent section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.

Respondent determined a deficiency in petitioner's 2000 Federal income tax and additions to tax as follows:

After concessions, ¹ the issues for decision are: (1) Whether petitioner received unreported income of $ 17,599.12 in wages, interest, dividends, and gains from the sale of stock for the 2000 taxable2004 Tax Ct. Summary LEXIS 157">*158 year; (2) whether petitioner is liable for an addition to tax under section 6651(a)(1) of $ 1,417.72 for the 2000 taxable year; and (3) whether petitioner is liable for an addition to tax under section 6654(a) of $ 337.35 for the 2000 taxable year.

Background

Some of the facts have been stipulated, and they are so found. The stipulation of facts and the attached exhibits are incorporated herein by this reference. ² At the time the petition was filed, petitioner resided in Sterling, Virginia.

2004 Tax Ct. Summary LEXIS 157">*159 During the 2000 taxable year, petitioner received the following: (1) Wages of $ 1,972 from the Loudon Baptist Temple; (2) interest of $ 1,643 from both Merrill Lynch Pierce Fenner & Smith (Merrill Lynch) and Prudential Securities, Inc. (Prudential); (3) dividends of $ 1,561 from Merrill Lynch and Prudential; ³ and (4) an income tax refund of $ 114 from the Commonwealth of Virginia Department of Tax.

On March 9, 2000, petitioner sold 125 shares of Series A, 8.5 percent cumulative preferred stock in Americo (Americo stock) and received sale proceeds of $ 2,963. In January 1994, petitioner had purchased 560 shares of Americo stock for $ 13,864.50. The sale of Americo stock thus resulted in a loss of $ 131.75.

During the 2000 taxable year, petitioner also sold 769 shares of stock in Peco Energy Co. (Peco2004 Tax Ct. Summary LEXIS 157">*160 stock) and received sale proceeds of $ 31,581 through the following transactions: ⁴

The sale of Peco stock resulted in a gain of $ 12,554.87.

2004 Tax Ct. Summary LEXIS 157">*161 Petitioner made estimated tax payments of $ 254 for the 2000 taxable year. In addition, petitioner requested, and respondent granted, two extensions of time to file a tax return for the 2000 taxable year. Despite these extensions, petitioner did not file a return for the 2000 taxable year.

As we indicated earlier, respondent determined that petitioner received unreported income and that she is liable for certain additions to tax for the 2000 taxable year. Respondent further determined that petitioner's filing status is "married filing separate return" and that she is entitled to the standard deduction and a personal exemption deduction for the 2000 taxable year. ⁵

Discussion

Generally, the burden of proof is on the taxpayer. 2004 Tax Ct. Summary LEXIS 157">*162 Rule 142(a)(1). However, if the taxpayer satisfies the limitations under section 7491(a)(2) and introduces credible evidence with respect to any factual issue relevant to ascertaining the tax liability, then the Commissioner bears the burden of proof with respect to such issue. Sec. 7491(a). Moreover, if a taxpayer asserts a reasonable dispute with respect to the income reported on an information return and fully cooperates, then the Commissioner shall have the burden of producing reasonable and probative information in addition to such information return. Sec. 6201(d); Tanner v. Commissioner, 117 T.C. 237">117 T.C. 237 (2001), affd. 65 Fed. Appx. 508">65 Fed. Appx. 508 (5th Cir. 2003); McQuatters v. Commissioner, T.C. Memo. 1998-88. In the present case, petitioner has not satisfied the requirements of either section 6201(d) or 7491(a). Unless indicated otherwise, the burden of proof remains on the petitioner.

Unreported Income

A taxpayer's gross income includes all income from whatever source derived, including (but not limited to) compensation for services, gains derived from dealings in property, interest, and dividends. ⁶Sec. 61(a)(1), (3), (4), (7). In the present2004 Tax Ct. Summary LEXIS 157">*163 case, petitioner received wages of $ 1,972, dividends of $ 1,561, interest of $ 1,643, a gain of $ 12,554.87 from the sale of Peco stock, and a loss of $ 131.75 from the sale of Americo stock. Accordingly, petitioner's gross income for the 2000 taxable year is $ 17,599.12. We sustain respondent's determination on this issue to the extent of this amount.

2004 Tax Ct. Summary LEXIS 157">*164 Addition to Tax Under Section 6651(a)(1)

If a Federal income tax return is not timely filed, an addition to tax will be assessed "unless it is shown that such failure is due to reasonable cause and not due to willful neglect". Sec. 6651(a)(1). A delay is due to reasonable cause if "the taxpayer exercised ordinary business care and prudence and was nevertheless unable to file the return within the prescribed time". Sec. 301.6651-1(c)(1), Proced. & Admin. Regs.; see also United States v. Boyle, 469 U.S. 241">469 U.S. 241, 469 U.S. 241">243 (1985). The Commissioner has the burden of production with respect to the liability of any individual for an addition to tax under section 6651(a)(1). Sec. 7491(c). The burden of showing reasonable cause under section 6651(a) remains on petitioner. Higbee v. Commissioner, 116 T.C. 438">116 T.C. 438, 116 T.C. 438">446-448 (2001).

In the present case, respondent met his burden of production with respect to the addition to tax under section 6651(a)(1). Petitioner did not file a return for the 2000 taxable year. Nor did petitioner provide any evidence to establish she had reasonable cause for the failure to timely file. Respondent's determination as to this issue is sustained.

2004 Tax Ct. Summary LEXIS 157">*165 Addition to Tax Under Section 6654

Section 6654(a) provides for an addition to tax "in the case of any underpayment of estimated tax by an individual". The amount of the underpayment is the excess of the "required installment" over the amount (if any) of the installment paid on or before the due date for the installment. Sec. 6654(b)(1). The amount of the required installment, in turn, is 25 percent of the required annual payment, which is the lesser of (1) 90 percent of the tax shown on the return for the taxable year (or, if no return is filed, 90 percent of the tax for such year), or (2) if the taxpayer filed a return for the immediately preceding taxable year, 100 percent of the tax shown on the return of the individual for the preceding taxable year. Sec. 6654(d)(1)(A) and (B). The Commissioner bears the burden of production in any court proceeding with respect to the addition to tax under section 6654. See sec. 7491(c). The Commissioner need only make a prima facie case that imposition of the addition to tax is appropriate. Mackey v. Commissioner, T.C. Memo. 2004-70.

In the present case, respondent did not meet his burden of production to establish a prima2004 Tax Ct. Summary LEXIS 157">*166 facie case that imposition of the addition to tax is appropriate. Petitioner made estimated tax payments of $ 254 for the 2000 taxable year. We cannot conclude from the record whether this amount is sufficient as the required annual payment under section 6654(d)(1)(B) because we cannot make a comparison with the tax shown on the return for the preceding taxable year. Accordingly, we deny respondent's determination regarding this issue.

Reviewed and adopted as the report of the Small Tax Case Division.

To reflect the foregoing,

Decision will be entered under Rule 155.