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for that year any of the $170,000 settlement. We have found that
petitioner is required to include the entire amount of that
settlement in gross income for her taxable year 1994.
On the record before us, we find that petitioner has failed
to carry her burden of showing that any of the exceptions in
section 6654(e) applies.9 On that record, we further find that
petitioner is liable for her taxable year 1994 for the addition
to tax under section 6654(a).
We have considered all of the contentions and arguments of
the parties that are not discussed herein, and we find them to be
without merit, irrelevant, and/or moot.
To reflect the foregoing and the concession of respondent,
Decision will be entered for
respondent except with respect to
the addition to tax under section
6651(a)(2).
9Petitioner failed to present evidence, and does not argue,
that any of the exceptions in sec. 6654(e) applies.
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