- 3 - abated with respect to the audit years preclude him from prevailing with respect to the deficiencies and additions to tax remaining at issue, (2) amounts petitioner remitted at the time of filing extension requests for 1996 and 1997 reduce the deficiencies determined for those years, and (3) respondent has satisfied his burden of production under section 7491(c) with respect to the section 6654(a) additions to tax remaining at issue. Unless otherwise noted, all section references are to the Internal Revenue Code in effect for the years at issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. Background The parties have filed a stipulation of facts and have submitted this case without trial pursuant to Rule 122. The stipulation of facts, with accompanying exhibits, is incorporated herein by this reference. We have inferred additional facts from uncontested portions of the parties’ submissions. We shall set forth only such facts as are necessary to understand our discussion and conclusion. At the time he filed the petition, petitioner resided in Arlington, Texas. Although he requested an extension of time to file his Federal income tax return for each of the audit years, petitionerPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011