Jesse S. Frederick - Page 8

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          1991)), affd. without published opinion 15 F.3d 1087 (9th Cir.               
          1993); see also Aldrich v. Commissioner, T.C. Memo. 1993-290,                
               Finally, petitioner argues that the Court does not have                 
          jurisdiction over additions to tax.  Petitioner is incorrect.                
          Our jurisdiction in this case is based on the valid notice of                
          deficiency issued by respondent and the timely filed petition.               
          See Rule 13(a), (c); Normac, Inc. v. Commissioner, 90 T.C. 142,              
          147 (1988).  Section 6214(a) gives the Court “jurisdiction to                
          redetermine the correct amount of the deficiency * * * and to                
          determine whether any additional amount, or any addition to the              
          tax should be assessed”.  Further, section 6665(a) provides that             
          in general additions to tax are to be paid, assessed, and                    
          collected in the same manner as taxes.  There is an exception to             
          section 6665(a) in section 6665(b), but the exception does not               
          apply in the two situations present in the instant case; namely,             
          the portion of the addition to tax under section 6651(a) that is             
          attributable to the deficiency, and the entire addition to tax               
          under section 6654 where no return is filed.  See sec. 6665(b)(1)            
          and (2); Estate of DiRezza v. Commissioner, 78 T.C. 19 (1982);               
          Reese v. Commissioner, T.C. Memo. 1997-346.                                  
               Petitioner has the burden of proof.  See Rule 142(a); Welch             
          v. Helvering, 290 U.S. 111, 115 (1933).  As noted, petitioner                
          does not dispute the facts in this case.  Thus, we find that                 

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