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The record establishes that petitioner failed to pay the
required amount of estimated tax for 1998. We conclude that
respondent has met his burden of production as to this issue.
Given that the record does not establish that any of the
referenced exceptions applies, we conclude that petitioner has
failed to meet his burden of proof and sustain respondent's
determination as to this issue. See Motley v. Commissioner, T.C.
Memo. 2001-257.
___________________________________
All arguments made by the parties and not discussed herein
have been rejected as meritless.
Decision will be
entered under Rule 155.
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Last modified: May 25, 2011