- 16 - and has not shown that any of the statutory exceptions are applicable.11 Respondent’s determination as to the addition to tax under section 6654(a) is sustained. Reviewed and adopted as the report of the Small Tax Case Division. To reflect the foregoing, Decision will be entered under Rule 155. 11 The burden remains upon petitioner to establish the applicability of any exceptions. Higbee v. Commissioner, supra at 446; Spurlock v. Commissioner, T.C. Memo. 2003-248.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17
Last modified: May 25, 2011