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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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