- 4 - without merit. The notice was mailed to and actually received by petitioner at his last known address. Sec. 6212(b); see Erhard v. Commissioner, 87 F.3d 273 (9th Cir. 1996), affg. T.C. Memo. 1994-344; Frieling v. Commissioner, 81 T.C. 42, 53 (1983). We find that the notice is valid and turn to the question of whether respondent correctly determined petitioner's tax liability. Respondent's determination that petitioner is liable for a $16,842 deficiency is presumed correct, and petitioner bears the burden of proving it erroneous. Rule 142(a); Welch v. Helvering, 290 U.S. 111, 115 (1933). Petitioner conceded that he received wages, but contended that his "hard work [did not] [constitute] * * * taxable income." Petitioner's contention is groundless. Accordingly, we reject it and hold that petitioner is liable for the deficiency. Respondent also determined that petitioner, pursuant to section 6654, is liable for an addition to tax for failing to make estimated tax payments. Petitioner has the burden of proving that respondent's determination is erroneous. Rule 142(a); Baldwin v. Commissioner, 84 T.C. 859, 871 (1985). Petitioner did not offer any evidence relating to this issue. Therefore, we hold that petitioner is liable for the section 6654 addition to tax. Respondent also determined that petitioner, pursuant to section 6651, is liable for an addition to tax for failing to file a tax return in a timely manner. In response, petitionerPage: Previous 1 2 3 4 5 Next
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