- 15 - at trial or on brief and has failed to propose any findings of fact that would lead to the conclusion that any of the exceptions found in section 6654(e) applies to petitioner. Petitioner has failed to prove facts to contradict respondent’s determination of an addition to tax in the amount of $1,029.42 under section 6654(a). Therefore, we sustain respondent's determination of an addition to tax under section 6654(a), subject only to recalculation of the deficiency. Decision will be entered under Rule 155.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15
Last modified: May 25, 2011