- 16 - Respondent has satisfied his burden of production under section 7491(c) by establishing that petitioner received the income items that he failed to report. Petitioner does not dispute receiving the payments and offered no reasonable cause for his failure to report the items. The Court holds that petitioner is liable for the accuracy- related penalty under section 6662(a). Reviewed and adopted as the report of the Small Tax Case Division. Decision will be entered under Rule 155.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17
Last modified: May 25, 2011