Connors v. Commissioner of Internal Revenue
Court of Appeals for the Second Circuit
1Opinion of the Court
SUMMARY ORDER
Cliff Connors appeals from a February 13, 2007 decision of the Tax Court (Cohen, J.) finding that Connors owed a tax deficiency for 2002 and owed additions to that deficiency for failure to file a tax return and failure to pay tax. We assume the parties’ familiarity with the facts and procedural history of the case.
Connors asserts five main arguments on appeal: (1) the Tax Court should have shifted the burden of proof to the government pursuant to Internal Revenue Code (“IRC”) § 7491(a); (2) the Tax Court should have granted Connors’s motion for a continuance so that he could…
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