What is the burden of proving negligence against the Commissioner for Excavation when determining that the Commissioner has made a mistake in imposing additional tax increases?
MultiRegion, United States of America
The following excerpt is from Larsen v. C.I.R., 765 F.2d 939 (9th Cir. 1985):
Once the Commissioner has determined that additions to tax should be imposed, those additions are presumptively correct. The taxpayer has the burden of proving his lack of negligence under 26 U.S.C. Sec. 6673. See Hall v. C.I.R., 729 F.2d at 635. This court has routinely affirmed the placing of this burden on the taxpayer. Id., and cases cited therein.
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