Walter Van Eck and Friedgard Van Eck - Page 45

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          Accordingly, the entire underpayments for the years 1982 through            
          1986 are due to negligence, and we sustain respondent's additions           
          to tax under section 6653(a) for such years.                                
               Petitioners have made no specific argument with regard to              
          the additions to tax for negligence for 1987 and 1988.                      
          Petitioners have failed to carry their burden of proving that               
          they were not negligent.  Accordingly, the entire underpayments             
          for the years 1987 and 1988 are due to negligence, and we sustain           
          respondent's additions to tax under section 6653(a) for such                
          years.                                                                      

                                                  Decision will be entered            
                                             under Rule 155.                          

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