- 3 - payment of $1,734 on account of disability from Metlife Agent. Respondent’s records do not reflect the filing of Federal income tax returns for 2001 and 2002 by petitioner. Respondent determined that petitioner had unreported income in the aforementioned amounts for 2001 and 2002, as well as additions to tax under section 6651(a)(1) for failing to file returns for each of those years. OPINION Unreported Income Petitioner’s admissions at trial, the deemed stipulations, and/or respondent’s evidence establish that petitioner received the income determined by respondent in 2001 and 2002, as outlined in our findings of fact. Her arguments that this income was not taxable are frivolous tax protester arguments that we need not “refute * * * with somber reasoning and copious citation of precedent; to do so might suggest that these arguments have some colorable merit.” Crain v. Commissioner, 737 F.2d 1417, 1417 (5th Cir. 1984) (per curiam). Accordingly, the deficiencies determined by respondent are sustained. Section 6651(a)(1) Additions to Tax Under section 7491(c), respondent has the burden of production with respect to petitioner’s liability for the section 6651(a)(1) additions to tax. In order to meet that burden, respondent must offer sufficient evidence to indicate that it isPage: Previous 1 2 3 4 5 6 7 NextLast modified: November 10, 2007