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are wrong. Rule 142(a); Welch v. Helvering, 290 U.S. 111, 115
(1933); sec. 7491(a).
Petitioner alleges no facts and advances no arguments
establishing error in respondent’s determinations for 1999 that
petitioner had unreported income for 1999 totaling $51,417 and
that petitioner’s filing status for that year was married filing
separate. Nor does petitioner allege any facts or advance any
arguments establishing that respondent is wrong in determining
that he is liable for 1999 for the accuracy-related penalty under
section 6662(a) because of (1) negligence or disregard of rules
or regulations under section 6662(b)(1) or (2) a substantial
understatement of tax under section 6662(b)(2).5
Instead, petitioner denies in the petition that he is liable
for the “$9,823.00 increase in tax” and the “$1,965.00 in penal-
ties” that respondent determined in the notice. In support of
those denials, petitioner relies on allegations that the Court
finds to be frivolous and/or groundless.6
5Petitioner reported total income of $0 and total tax of $0
in his 1999 return for that year. We conclude that respondent
has satisfied respondent’s burden of production under sec.
7491(c) with respect to the accuracy-related penalty determined
in the notice.
6For example, petitioner alleges in the petition:
3) Petitioner disputes the following:
* * * * * * *
C) That the letter 1384(SC) is a legal
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Last modified: May 25, 2011