or 10 percent of the tax required to be shown on the return. Sec.
6661(b)(1)(A). An amount may be reduced, however, if the taxpayer shows that
there was substantial authority for such treatment of the item, or that the
relevant facts affecting the tax treatment of the item are adequately
disclosed on the return or in a separate statement attached to the return.
Sec. 6661(b)(2)(B). Respondent's determinations are presumed correct, and Mr.
Burke bears the burden of proving otherwise. Rule 142(a); Hall v.
Commissioner, 729 F.2d 632, 635 (9th Cir. 1984), affg. T.C. Memo. 1982-337;
Bixby v. Commissioner, 58 T.C. 757, 791-792 (1972); Kerr v. Commissioner, T.C.
Memo. 1990-155.
Mr. Burke did not address this issue on brief. We sustain the additions
to tax pursuant to section 6661 as determined in the notice of deficiency and
hold that Mr. Burke is also liable for this addition to tax with respect to
the understatement of tax attributable to additional income of $22,448, which
we have found for 1986.
Decision will be entered
under Rule 155.
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