George Georgiou and Judith Georgiou A.K.A. Judy Georgiou, et al. - Page 43

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            B.  Sections 6653(a) and 6661 Additions to Tax                                                 
                  Respondent determined an addition to tax for Kolonaki in                                 
            1989, under sections 6653(a)(1) and 6661.  Kolonaki did not                                    
            present any evidence on the negligence and substantial                                         
            understatement determinations for the 1989 tax year.  Because                                  
            Kolonaki did not meet its burden of proof, we sustain                                          
            respondent's determination that Kolonaki is liable for the                                     
            additions to tax under sections 6653(a)(1) and 6661 for 1989.                                  
                  Respondent has conceded the additions to tax under sections                              
            6653(a) and 6661 with respect to GRS.                                                          
                  To reflect the foregoing and concessions of the parties,                                 
                                                              Decisions will be entered                    
                                                        under Rule 155.                                    
























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