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section 6653(a). Condor Intl., Inc. v. Commissioner, 98 T.C.
203, 225 (1992).
The arguments petitioners have presented to contest the
addition to tax under section 6653(a) are the same arguments that
we have assessed and rejected above. It would serve no purpose
to repeat that discussion. Petitioners have not carried their
burden of proof.
To reflect the foregoing,
Decisions will be entered
for respondent.
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