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Respondent has met his burden of production because
petitioner failed to remit, in whole or in part, estimated tax
payments for 1994, 1996, and 1997. Petitioner has not shown that
any of the statutory exceptions are applicable. Respondent’s
determination as to the addition to tax under section 6654(a) is
sustained.
Reviewed and adopted as the report of the Small Tax Case
Division.
To reflect the foregoing,
Decision will be entered
for respondent.
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Last modified: May 25, 2011