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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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