- 2 -
an addition to tax under sec. 6651(a)(2). In his petition,
petitioner questioned the entire deficiency, alleging that
respondent was in error and more specifically that respondent’s
agent had no authority to conduct an examination and that
petitioner was not afforded due process2 during the
administrative examination procedures. Respondent has orally
moved that the Court award sanctions under section 6673, alleging
that petitioner’s position is frivolous and interposed merely for
delay. We consider the following issues in this opinion: (1)
Whether petitioner has shown that respondent’s determination is
in error, and (2) whether petitioner is liable for the additions
to tax under sections 6651(a)(1), 6651(a)(2), and 6654(a); and
(3) whether damages should be awarded under section 6673.
2 Petitioner has not made clear how he was not afforded “due
process” or what he means by that term.
Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011