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to meet his burden of proof. Accordingly, we hold that
petitioners are not liable for the deficiencies relating to 1993.
II. Respondent's Other Determinations
Respondent determined that: (1) For 1992, petitioners were
each liable for a 10-percent additional tax on early
distributions they received from their IRA's; and (2) for 1992
and 1993, petitioners were each liable for self-employment tax,
additions to tax for failure to file timely Federal income tax
returns, and additions to tax for failure to make estimated tax
payments. We have held for 1993 that petitioners are not liable
for deficiencies relating to respondent's determination that they
received income. As a result, petitioners are not liable for the
self-employment tax and additions to tax relating to 1993.
Petitioners bear the burden of proving that the determinations
relating to 1992 are erroneous. Rule 142(a). Petitioners
introduced no evidence relating to these determinations.
Therefore, they are liable for the taxes and additions to tax
relating to 1992.
III. Respondent's Motion for a Section 6673 Penalty
Respondent submitted a motion for the imposition of a
penalty under section 6673. Section 6673(a)(1) authorizes this
Court to impose a penalty in favor of the United States in an
amount not to exceed $25,000 whenever it appears that the
taxpayer's position in a proceeding is frivolous, groundless, or
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