- 29 - 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.Page: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29
Last modified: May 25, 2011