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Petitioner has not shown (1) that he had substantial
authority for the position taken on his 1983, 1984, and 1985 tax
returns, or (2) that he adequately disclosed his position in a
statement attached to these tax returns or on these tax returns.
Petitioner also has not shown that he had reasonable cause for the
understatement, and that he acted in good faith.
Petitioner has failed to carry his burden of proof.
We hold for respondent on this issue.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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