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bears the burden of establishing that he is not liable for the
accuracy-related penalty); Espinoza v. Commissioner, T.C. Memo.
1999-269 (holding that the taxpayer bears the burden of proof on
the issue of a section 6651 addition to tax.) Accordingly, we
sustain respondent's determination that the Bullocks are liable for
the section 6651(a)(1) addition to tax to the extent of the
underpayment relating to the disallowed Schedule C deductions for
1993 and 1994. We likewise sustain respondent’s determination that
the Bullocks are liable for the accuracy-related penalties under
section 6662(a) for both years.
In reaching our conclusions herein, we have considered all
arguments presented and, to the extent not discussed above, find
them to be irrelevant or without merit.
To reflect the foregoing and respondent's concessions,
Decisions will be
entered under Rule 155.
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Last modified: May 25, 2011