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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 that
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