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and Petitioner Dennis P. Raquet. In the Stipulation of Settle-
ment between Respondent and Petitioner Dennis P. Raquet, peti-
tioner Dennis P. Raquet agreed to the deficiencies and additions
to tax for the taxable years 1979 through 1982, including the
increased deficiency of $29,913 for the 1982 tax year. Also at
the calendar call, respondent filed with the Court a Motion to
Dismiss for Lack of Prosecution as to petitioner Diana C. Raquet.
OPINION
Burden of Proof
Respondent bears the burden of proof with respect to an
increased deficiency. Here, respondent increased the deficiency
determined in the notice of deficiency in her Amendment to
Answer. The increase in deficiency was due to a clerical error
in the preparation of petitioner's notice of deficiency. In the
context of a case such as the one before us, where the increase
in deficiency is based on a clerical or mathematical error in the
notice of deficiency, respondent bears only the burden of estab-
lishing the clerical or mathematical error. Petitioner retains
the burden with regard to respondent's determinations. See
Estate of Applestein v. Commissioner, 80 T.C. 331, 347 n.5
(1983); Beck Chem. Equip. Corp. v. Commissioner, 27 T.C. 840, 856
(1957); see also Kiehl v. Commissioner, T.C. Memo. 1986-54; Holtz
v. Commissioner, T.C. Memo. 1982-436. We find that respondent
has met this burden of establishing the clerical error through
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