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has (1) adequately disclosed his or her position, or (2) has
substantial authority for the tax treatment of an item.
Sec. 6661; sec. 1.6661-6(a), Income Tax Regs.
The daughters bear the burden of proof with regard to the
additions to tax determined by respondent. Rule 142(a).
In their petitions, both of the daughters assign error to
respondent's determinations of additions to tax under sections
6653(a) and 6661. Neither of the daughters, however,
specifically avers any facts in support of those assignments of
errors. On brief, the daughters propose no findings of fact
specifically relating to the additions to tax, nor do they set
forth any arguments with regard to the additions to tax. We
assume that, in defense to respondent's determinations of
additions to tax, the daughters rely exclusively on our
determining no deficiencies in tax liability. We have determined
such deficiencies. The daughters have failed to carry their
burdens of proof. Respondent's determinations of additions to
tax with respect to the daughters are sustained.
Decisions will be entered
for respondent in docket Nos.
345-92 and 352-92.
Decision will be entered
for petitioners in docket No.
900-92.
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