- 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