- 6 - those years. See sec. 6651(g)(2). Accordingly, petitioner is not to be treated as having failed to pay a tax reflected on tax returns for the years in issue. Petitioner is not liable for an addition to tax under section 6651(a)(2). See Cabirac v. Commissioner, 120 T.C. ___ (2003), and sec. 7491(c), which places the burden of production on respondent with regard to additions to tax. Because of petitioner’s frivolous arguments herein, we shall impose on petitioner under section 6673(a)(1)(B) a penalty equal to $2,000. To reflect the foregoing, Decision will be entered under Rule 155.Page: Previous 1 2 3 4 5 6
Last modified: May 25, 2011