- 7 - section 6501 for that year had expired. Discussion Petitioner has introduced no credible evidence with respect to any factual issue relevant to ascertaining whether the deter- minations in the notice are erroneous. We find that petitioner has the burden of proving that those determinations are wrong. Rule 142(a); Welch v. Helvering, 290 U.S. 111, 115 (1933); sec. 7491(a). Petitioner proffered no evidence and advanced no argument establishing that respondent’s determination that he had wage income for 1997 totaling $26,690 is in error. Indeed, petitioner concedes in the parties’ stipulation of facts in this case that he had that amount of wage income for that year. Nor has petitioner proffered any evidence or advanced any argument establishing that respondent is wrong in determining that he is liable for his taxable year 1997 for additions to tax under sections 6651(a)(1) and 6654(a).4 We now turn to section 6673(a)(1), a provision that the Court brought to petitioner’s attention several times both before and during the trial in this case. The Court specifically advised petitioner before and during trial that the questions, 4Petitioner conceded on cross-examination at trial and in petitioner’s supplement to petitioner’s trial memorandum that he did not file a return for his taxable year 1997. We conclude that respondent has satisfied respondent’s burden of production under sec. 7491(c).Page: Previous 1 2 3 4 5 6 7 8 9 Next
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