- 22 - homeowner's insurance attributable to petitioners' home office, renter's insurance attributable to petitioners' home office, and hazard insurance on petitioners' residence, and mortgage insurance. However, petitioners failed to introduce any evidence showing that they are entitled to a larger deduction than the amount allowed by respondent. Consequently, petitioners have not met their burden of proof, and we sustain respondent with respect to this issue. Interest Expenses for 1990 For the taxable year 1990 petitioners deducted "other interest" in the amount of $1,130. Of this amount, respondent disallowed $282. Although petitioners, on brief, explain that the interest deducted is attributable to vehicles used in their business, they failed to introduce any evidence that they are entitled to a larger deduction than the amount allowed by respondent. See Rule 143(b). Consequently, petitioners have not met their burden of proof, and we sustain respondent with respect to this issue. Issue 4. Section 6653(a)(1) Addition to Tax for Negligence for 1988 Respondent determined an addition to tax for negligence under section 6653(a)(1) against petitioners for their 1988 taxable year. For that year, section 6653(a)(1) imposes an addition to tax equal to 5 percent of the underpayment of the tax required to be shown on a taxpayer's return if any part of thatPage: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Next
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