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payment for 2002 that was payable in installments under section
6654. Therefore, the Court finds respondent failed to meet his
burden of production. Accordingly, respondent’s determination
regarding the section 6654 addition to tax is not sustained.
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 as to the
deficiency and the addition to
tax under section 6651(a)(1),
and for petitioner as to the
additions to tax under
sections 6651(a)(2) and 6654.
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Last modified: March 27, 2008