Terry R. Hardtke and Nancy Hardtke - Page 9

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          6653(a)(1)(A) and (B) and the addition to tax for a substantial             
          understatement of income tax under section 6661(a).  Petitioners            
          presented no evidence and make no argument regarding the addi-              
          tions to tax under section 6653(a)(1)(A) and (B) and section                
          6661(a) for 1987.  Consequently, petitioners have failed to                 
          satisfy their burden of proof on those issues.  See Rule 142(a);            
          Niedringhaus v. Commissioner, 99 T.C. 202, 220-222 (1992); Crown            
          Income Charitable Fund v. Commissioner, 98 T.C. 327, 339 (1992),            
          affd. 8 F.3d 571 (7th Cir. 1993).  Accordingly, we sustain                  
          respondent's determinations that petitioners are liable for 1987            
          for the additions to tax under section 6653(a)(1)(A) and (B) and            
          section 6661(a).                                                            
               To reflect the foregoing,                                              
                                             Decision will be entered                 
                                        for respondent.                               





















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