Anna E. Charlton - Page 7

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          computational adjustment only and no new issue is raised by the             
          amended answer.  We shall therefore grant respondent's motion to            
               All of the material allegations set forth in the petition in           
          support of assignments of error were denied in respondent's                 
          answer.  Accordingly, the burden of proof rests with petitioner             
          concerning any error in the deficiency respondent determined for            
          the 2002 taxable year, and petitioner has adduced no evidence in            
          support of the assignments of error made in the petition.                   
               In his amended answer, respondent asserted additions to tax            
          under sections 6651(a)(1) and 6654(a) for which, pursuant to                
          section 7491(c), respondent generally bears the burden of                   
          production to show that imposition of the additions to tax is               
          appropriate.  See Higbee v. Commissioner, 116 T.C. 438, 446                 
          (2001).  Rule 34(b)(4) provides that a petition in a deficiency             
          action shall contain clear and concise assignments of "each and             
          every error" in the Commissioner's determination as well as                 
          statements of the facts upon which the taxpayer bases the                   
          assignments of error.  Where the taxpayer has not made the                  
          foregoing specific allegations, the Commissioner incurs no burden           
          of production with respect to the additions to tax that have been           
          determined.  Funk v. Commissioner, 123 T.C. 213, 215 (2004).                
               The petition in this case does not contain any specific                
          allegations regarding the additions to tax or of facts to support           

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