Charles C. Jones - Page 4

                                        - 4 -                                         
          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                          
                                                             (continued...)           




Page:  Previous  1  2  3  4  5  6  Next

Last modified: May 25, 2011