- 6 - 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.Page: Previous 1 2 3 4 5 6
Last modified: May 25, 2011