- 14 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14
Last modified: May 25, 2011