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Respondent also determined an addition to tax for
substantial understatement of tax liability under section 6661
for 1988. Petitioners have not shown that any of the exceptions
contained in section 6661(b) apply. The amount of any addition
to tax pursuant to section 6661 will be computed under Rule 155.
Petitioners have the burden of proof on the additions to tax
and penalty issues, which they have failed to carry. Bixby v.
Commissioner, 58 T.C. 757 (1972); see Grzegorzewski v.
Commissioner, T.C. Memo. 1995-49. Respondent's determinations of
the additions to tax and penalty issues are therefore sustained.
To reflect the above,
Decision will be entered
under Rule 155.
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