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D. Conclusion
During the years in issue, petitioner was not at risk on
account of either installment note. We therefore uphold
respondent's determinations of deficiencies in tax as they relate
thereto.
II. Additions to Tax
A. Negligence
Section 6653(a) imposes one addition to tax, and, in some
cases, two additions to tax, where the taxpayer's underpayment is
due to negligence or intentional disregard of rules or
regulations (hereinafter referred to simply as negligence).
Section 6653(a), as applicable for 1980, and section 6653(a)(1),
as applicable for 1981 through 1983, impose an addition to tax
equal to 5 percent of the entire underpayment if any portion of
such underpayment is due to negligence. Section 6653(a)(2), as
applicable for 1981 through 1983, imposes an addition to tax
equal to 50 percent of the interest payable under section 6601
with respect to the portion of the underpayment due to negligence
(the interest-sensitive addition to tax). Petitioners bear the
burden of proof. Rule 142(a).
An underpayment, for purposes of section 6653(a), is the
amount by which the tax liability exceeds the tax shown on a
timely filed return. Secs. 6653(c)(1), 6211(a). The parties
have stipulated that petitioners did not timely file their 1980
and 1981 Federal income tax returns. Therefore, for 1980 and
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