Renard Halliburton - Page 8




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          payment for 2002 that was payable in installments under section             
          6654.  Therefore, the Court finds respondent failed to meet his             
          burden of production.  Accordingly, respondent’s determination              
          regarding the section 6654 addition to tax is not sustained.                
               In reaching these holdings, the Court has considered all               
          arguments made and, to the extent not mentioned, concludes that             
          they are moot, irrelevant, or without merit.                                
               To reflect the foregoing,                                              
                                                  Decision will be entered            
                                             for respondent as to the                 
                                             deficiency and the addition to           
                                             tax under section 6651(a)(1),            
                                             and for petitioner as to the             
                                             additions to tax under                   
                                             sections 6651(a)(2) and 6654.            





















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