- 23 -
T.C. 934, 947 (1985) (quoting Marcello v. Commissioner, 380 F.2d
499, 506 (5th Cir. 1967), affg. in part and remanding in part 43
T.C. 168 (1964)). The taxpayer has the burden of proving that
the Commissioner's determination of the additions to tax under
section 6653(a) is erroneous. Rule 142(a); Bixby v. Commis-
sioner, 58 T.C. 757 (1972).
Petitioners have not presented evidence to establish that
they were not negligent or did not disregard rules or
regulations. Petitioners did not maintain records, as required
by law, and failed to sustain their burden of proof on the
disputed issues. On this record, we sustain respondent's
determination that petitioners are liable for the additions to
tax under section 6653(a).
To reflect the foregoing,
Decision will be entered
under Rule 155.
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