- 9 - burden of production. See, e.g., Spurlock v. Commissioner, T.C. Memo. 2003-124. Petitioner did not specifically address his liability for the addition to tax, and the evidence in the record lacks any indication that his failure to file was due to reasonable cause and not willful neglect. Accordingly, we hold that petitioner is liable for the addition to tax under section 6651(a)(1) for the years in issue. Decision will be entered under Rule 155.Page: Previous 1 2 3 4 5 6 7 8 9
Last modified: May 25, 2011