Alex B. Rhodes, Jr. - Page 6

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          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.                                 























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