- 13 -13 his argument that the Weisel payment is excludable under section 104(a)(2). Petitioner has failed to carry his burden of proof and, thus, petitioner is liable for the penalty imposed by section 6662(a). Decision will be entered for respondent.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13
Last modified: May 25, 2011