- 28 - Therefore, we find that respondent has carried his burden of production and petitioner has failed to negate his liability. Petitioner is liable for the addition to tax for failure to file a return pursuant to section 6651(a)(1). IV. Conclusion On the record before us, we hold that petitioner failed to meet his burden of proving entitlement to a dependency exemption deduction for his daughter for 2003. Furthermore, we find that in addition to the itemized deductions respondent conceded, petitioner would be entitled to an additional $65 deduction for medical and dental expenses. However, our findings do not alter respondent’s conclusion that petitioner is not entitled to itemized deductions in an amount greater than the standard deduction, and therefore we sustain his determination that petitioner is entitled only to the standard deduction. Finally, we find that petitioner has not demonstrated reasonable cause for failing to file his 2003 tax return. Therefore, we sustain the imposition of an addition to tax under section 6651(a). In reaching our holdings, we have considered all the parties’ contentions, and to the extent that we have not addressed them, we conclude that they are irrelevant, moot, or without merit.Page: Previous 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 NextLast modified: November 10, 2007