6
citation of precedent; to do so might suggest that these
arguments have some colorable merit." Crain v. Commissioner, 737
F.2d 1417 (5th Cir. 1984).
Petitioners have not shown that they incurred additional
expenses beyond those allowed by respondent or that their gross
income as determined in the notice of deficiency should be
reduced by any amount greater than that which respondent has
agreed to and conceded. It was petitioners' burden to make such
a showing. Rule 142(a); Welch v. Helvering, 290 U.S. 111 (1933).
Thus, respondent's determinations of the deficiency, as modified
to give effect to respondent's concessions herein, must stand.
The additions to tax for failure to file returns under
section 6651(a) for each of the years must likewise be approved.
A Form 1040 which contains only "object Fifth Amendment" entries
is not a Federal income tax return. Beard v. Commissioner, 82
T.C. 766, 777 (1984), affd. 793 F.2d 139 (6th Cir. 1986). This
is true even where information forms are attached to the form.
Reiff v. Commissioner, 77 T.C. 1169, 1177-1179 (1981).
Finally, petitioners have not alleged, let alone shown, that
they had any credible fear of prosecution that could remotely
justify claiming the Fifth Amendment with respect to the
reporting of any given item on their returns. Reiff v.
Commissioner, supra.
We also approve respondent's imposition of the addition to
tax for failure to pay estimated income tax under section 6654(a)
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