- 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.
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Last modified: May 25, 2011