Alfred L. and Renee E. Fields - Page 14




                                        - 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