proof, which is not lessened in a fully stipulated case. Rule
142(a); Tippin v. Commissioner, 104 T.C. 518, 533 (1995);
Borchers v. Commissioner, 95 T.C. 82, 91 (1990), affd. 943 F.2d
22 (8th Cir. 1991). Petitioner has conceded that the returns for
both years at issue were filed delinquently and has offered no
other evidence on the issues of additions to tax and penalties,
which he did not address in his brief. Accordingly, we sustain
respondent's determinations.
To reflect the foregoing, and concessions of the parties,
Decision will be
entered under Rule 155.
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Last modified: May 25, 2011