- 8 - 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.Page: Previous 1 2 3 4 5 6 7 8 9Last modified: November 10, 2007