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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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Last modified: May 25, 2011