Yuri G. Glotov - Page 9




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               Therefore, respondent has met the burden of production, and            
          petitioner, having failed to show reasonable cause or other basis           
          for reducing the underpayment on which the penalty is imposed, is           
          liable for the section 6662 penalty for negligence for 2003.  See           
          sec. 1.6662-3(b)(3), Income Tax Regs.  The Court, in reaching its           
          holding, has considered all arguments made and concludes that any           
          arguments not mentioned above are moot, irrelevant, or without              
          merit.                                                                      
               To reflect the foregoing,                                              

                                                  Decision will be entered            
                                             for respondent.                          



























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