- 17 - hold that petitioners have failed in their burden of proof. Rule 142(a). We sustain respondent's disallowance of the car and truck expenses, and we sustain respondent’s imposition of the accuracy-related penalties under section 6662(a). Respondent filed a motion for partial summary judgment prior to trial. Because the issues raised therein have been decided in this opinion, respondent's motion for partial summary judgment will be denied as moot. Respondent’s motion for partial summary judgment will be denied as moot, and decision will be entered under Rule 155.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17
Last modified: May 25, 2011