- 6 - Petitioners received income in the amounts respondent determined and did not file income tax returns for the years in issue.5 Petitioners point out that respondent determined that petitioners are not entitled to deductions for business expenses to which petitioners claim they are entitled. However, petitioners offered no evidence contrary to respondent’s determination. We conclude that petitioners are each liable for deficiencies in the amounts that respondent determined for 1994, 1996, and 1997. B. Additions to Tax Petitioners admit that they did not file income tax returns for 1994, 1996, and 1997, and that they received income in those years in the amounts respondent determined. The parties stipulated to transcripts of account which show that (1) taxes were underwithheld from petitioners’ income for 1997 and (2) petitioners did not pay estimated tax for 1997. Respondent has met the burden of production under section 7491(c) as to the additions to tax under section 6651(a) for failure to file for 1994, 1996, and 1997, and under section 6654 for failure to pay 5 Petitioners do not contend and have offered no evidence showing that sec. 7491(a) applies in this case. Taxpayers bear the burden of proving that they have met the requirements of sec. 7491(a). H. Conf. Rept. 105-599, at 239 (1998), 1998-3 C.B. 747, 993; S. Rept. 105-174, at 45 (1998), 1998-3 C.B. 537, 581.Page: Previous 1 2 3 4 5 6 7 8 Next
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