- 5 -
addition to tax under section 6651(a)(2). Id. Respondent does
not allege and there is no evidence showing that respondent
prepared substitutes for returns for petitioner under section
6020(b). Thus, respondent has not produced evidence showing that
it is appropriate to impose the addition to tax for failure to
pay tax shown on petitioner’s returns for the years in issue, and
respondent has not met the burden of production under section
7491(c) with respect to that addition to tax.
Petitioner made only frivolous arguments that he was not
liable for tax. He made no argument that he was not liable for
the additions to tax for the years in issue for failure to file
under section 6651(a)(1), or failure to pay estimated tax under
section 6654. We conclude that petitioner is liable for the
additions to tax for 1998, 1999, and 2001 for failure to file
under section 6651(a)(1) and for failure to pay estimated tax
under section 6654.
To reflect the foregoing,
Decision will be
entered under Rule 155.
Page: Previous 1 2 3 4 5
Last modified: May 25, 2011