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The petition in the instant case did not contain any
specific allegations regarding any of the three additions to tax
or facts to support any such allegations. Therefore, these
issues are all deemed conceded by petitioner, and respondent has
no burden of production under section 7491(c). See Funk v.
Commissioner, supra; Swain v. Commissioner, 118 T.C. 358, 363-364
(2002).
Accordingly, respondent’s motion to dismiss for failure
properly to prosecute will be granted.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011