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In the present case, respondent met his burden of production
with respect to the addition to tax under section 6651(a)(1).
Petitioner did not provide any evidence as to the reasons for the
late filing for the 2000 taxable year. Nor did petitioner
provide any evidence to establish he had reasonable cause for the
failure to timely file. Respondent’s determination as to this
issue is sustained.
Reviewed and adopted as the report of the Small Tax Case
Division.
To reflect the foregoing,
Decision will be entered
under Rule 155.4
4 As previously indicated, the Court was not provided with
a complete copy of the notice of deficiency, which would
presumably contain a copy of the adjustments. Accordingly, we
assume that the mutual concessions made by the parties, as stated
supra note 3, related to adjustments in the notice of deficiency
and that the amount of the deficiency and addition to tax will be
less than that determined as a result of concessions.
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Last modified: May 25, 2011