- 19 - burden of production, and petitioner, having failed to show reasonable cause, substantial authority, or other basis for reducing the underpayment on which the penalty is imposed, is liable for the section 6662 penalty for 2001. 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 under Rule 155.Page: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19Last modified: November 10, 2007