Duyet Minh Nguyen - Page 9




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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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