- 30 -                                        
               Respondent determined in her notice of deficiency that                 
          petitioner is liable for additions to tax under section 6651(a)             
          in amounts equal to 25 percent of the underpayments for 1983 and            
          1984.  In her answer, respondent conceded that this addition was            
          not due for 1983.  On brief, respondent conceded that if we                 
          determine that petitioner is not liable for the addition to tax             
          for fraud under section 6653(b) for 1984, then petitioner is                
          liable for no more than a 10-percent addition to the underpayment           
          under section 6651(a).                                                      
               Petitioner offered no proof that he timely filed his return            
          for 1984, or that the late filing was due to reasonable cause and           
          not willful neglect.  Petitioner has not carried his burden.  We            
          therefore sustain respondent's determination that petitioner is             
          liable for the 10 percent addition to tax under section 6651(a)             
          for 1984.                                                                   
               To reflect the foregoing,                                              
                                      Decision will be entered under                  
                                      Rule 155.                                       
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