- 43 - 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.Page: Previous 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43
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