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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.
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Last modified: November 10, 2007