David and Monika Zisskind - Page 8

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               Because the underlying income tax liability was self-                  
          assessed, petitioners did not receive a notice of deficiency.               
          The parties agree petitioners have not had an opportunity to                
          dispute their liability for the addition to tax under section               
          6651(a)(2).  Therefore, we review de novo whether petitioners are           
          liable for the addition to tax under section 6651(a)(2).  See               
          Downing v. Commissioner, 118 T.C. 22, 29 (2002); Ramirez v.                 
          Commissioner, T.C. Memo. 2005-179; Godwin v. Commissioner, T.C.             
          Memo. 2003-289, affd. 132 Fed. Appx. 785 (11th Cir. 2005).                  
          However, we review for an abuse of discretion respondent’s                  
          determinations rejecting an abatement of interest and sustaining            
          the Federal tax lien.  See Downing v. Commissioner, supra at 29;            
          Ramirez v. Commissioner, supra; Godwin v. Commissioner, supra;              
          see also sec. 6404(h)(1).                                                   
          A.   Addition to Tax Under Section 6651(a)(2)                               
               Section 6651(a)(2) imposes an addition to tax for failure to           
          pay the amount shown as a tax on a return by the date prescribed            
          (determined with regard to any extension of time for payment).              
          Section 7491(c) requires respondent to carry the burden of                  
          production with respect to the addition to tax for failure to               
          pay.  Higbee v. Commissioner, 116 T.C. 438, 446-447 (2001).  To             
          meet his burden of production, respondent must come forward with            
          sufficient evidence indicating that it is appropriate to impose             
          the addition to tax.  Id.  Once respondent meets this burden,               

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