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Therefore, respondent has met the burden of production, and
petitioner, having failed to show reasonable cause or other basis
for reducing the underpayment on which the penalty is imposed, is
liable for the section 6662 penalty for negligence for 2003. See
sec. 1.6662-3(b)(3), Income Tax Regs. The Court, in reaching its
holding, has considered all arguments made and concludes that any
arguments not mentioned above 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