- 9 - therefore, failed to satisfy their burden of proof to absolve them of liability under section 6651(a)(1). Rule 142(a); United States v. Boyle, 469 U.S. 241, 245 (1985). Respondent, therefore, is sustained on the addition to tax under section 6651(a)(1). Decision will be entered under Rule 155.Page: Previous 1 2 3 4 5 6 7 8 9
Last modified: May 25, 2011