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the corporation bear the burden of proving that respondent's
determinations of additions to tax are erroneous. Rule 142(a).
Neither petitioners nor the corporation objected to
respondent's requested ultimate findings of fact that the
underpayments of tax by petitioners and by the corporation "were
due to negligence and/or intentional disregard of rules and
regulations." Additionally, they make no argument on brief
concerning the additions to tax pursuant to section 6653.
Accordingly, we consider petitioners and the corporation to have
conceded the additions to tax pursuant to section 6653.
Petitioners and the corporation argue that, to the extent
that the threshold requirements of section 6661 are not met, the
section 6661 addition to tax does not apply. Neither petitioners
nor the corporation makes any argument concerning the additions
to tax pursuant to section 6651. Consequently, we consider the
additions to tax pursuant to sections 6651 and 6661 (to the
extent that the threshold requirements are met) to have been
conceded. Rybak v. Commissioner, 91 T.C. 524, 566 (1988).
Accordingly, we sustain respondent's determination of additions
to tax for petitioners and the corporation.
To reflect the foregoing,
Decisions will be entered
under Rule 155.
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