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support that his 1999 return was filed timely. Thus, petitioner
did not meet his burden of proof.
Accordingly, this Court finds that respondent correctly
determined that collection could proceed for 1997 and 1999. See
Boyd v. Commissioner, 117 T.C. 127, 131-132 (2001).
In reaching these holdings, the Court has considered all
arguments made and, to the extent not mentioned, concludes that
they are moot, irrelevant, or without merit.
To reflect the foregoing,
Decision will be
entered for respondent.
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Last modified: November 10, 2007