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Respondent determined that petitioner is liable for the
additions to tax discussed above. Petitioner has offered no
evidence with regard to any of the additions to tax. In fact,
petitioner's briefs fail to address the additions to tax. The
burden rests with petitioner to prove that respondent's
determinations are in error. Rule 142(a). We cannot be sure
that petitioner intended to abandon the issue, but in any case
respondent's determination of the applicable additions to tax
must be sustained with respect to any underpayment of tax or
substantial understatement resulting from the omission of income
in 1985 and from the constructive dividends in 1986 and 1987.
To reflect the foregoing and the concessions of the parties,
Decision will be entered
under Rule 155.
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