- 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.Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23
Last modified: May 25, 2011