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case, including petitioner’s admission that he did not file,
satisfies respondent’s burden as to the additions to tax under
the statute. Upon petitioner’s failure to file a return,
respondent caused a “Substitute for a Return” to be prepared
under section 6020(b). Accordingly, petitioner is liable for
additions to tax under section 6651(a)(1) and (2), and section
6654(a).
To reflect the foregoing,
Decision will be entered
under Rule 155.
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Last modified: November 10, 2007