11
1995. Thus, respondent meets the burden of production (if
applicable) under section 7491(c).5
Petitioner alleged in the petition that all of respondent’s
adjustments were wrong, but he offered no evidence and made no
argument on this issue. We conclude that petitioner is liable
for the addition to tax under section 6654 for failure to pay
estimated tax for 1995.
To reflect concessions and the foregoing,
Decision will be
entered under Rule 155.
5 As discussed in note 3, above, it appears that sec.
7491(c) does not apply in this case.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11
Last modified: May 25, 2011