- 14 - C. Whether Petitioner Is Liable for the Addition to Tax for Negligence in 1981 and 1982 Respondent determined and contends that petitioner is liable for the addition to tax for negligence under section 6653(a)(1) for 1981 and 1982. Petitioner did not dispute respondent’s contention at trial or on brief even though petitioner bears the burden of proof on this issue. See Rule 142(a). We treat petitioner’s failure to dispute respondent’s contention as his concession that respondent’s determination is correct. See Bradley v. Commissioner, 100 T.C. 367, 370 (1993); Stringer v. Commissioner, 84 T.C. 693, 706 (1985), affd. without published opinion 789 F.2d 917 (4th Cir. 1986); Bernstein v. Commissioner, 22 T.C. 1146, 1152 (1954), affd. per curiam 230 F.2d 603 (2d Cir.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
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