126 T.C. No. 8
UNITED STATES TAX COURT
NT, INC. d.b.a. NATURES TOUCH, Petitioner
v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 2725-05. Filed April 19, 2006.
On Feb. 14, 2005, P, a corporation, petitioned the
Court to redetermine R’s determination of Federal
income tax deficiencies, additions to tax under sec.
6651(a)(1), I.R.C., and accuracy-related penalties
under sec. 6662(a), I.R.C. Shortly thereafter, the
State in which P was organized suspended P’s corporate
powers, rights, and privileges for failing to pay State
income tax. R moves the Court to dismiss this case for
lack of prosecution to the extent that it relates to
deficiencies and to find without trial that P is liable
for the additions to tax and accuracy-related penalties
as determined. R asserts that P’s suspension precludes
it from prosecuting this case as to the deficiencies.
R asserts that he bears a burden of production under
sec. 7491(c), I.R.C., as to the additions to tax and
accuracy-related penalties, and that he has met this
burden.
Held: Pursuant to Rules 60(c) and 123(b), Tax
Court Rules of Practice and Procedure, the Court will
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Last modified: May 25, 2011