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annual or periodical" U.S. source income that it may receive.
Petitioners have presented no evidence of receiving advice that
depositing timely a tax in a Government depositary was
unnecessary. Consequently, we hold that petitioners have not
established reasonable cause and are therefore subject to the
section 6656(a) additions to tax relating to LTD’s income tax
liability for taxable years ended June 30, 1987 through 1989, and
LTD’s withholding tax liability for calendar years 1985 and 1986.
5. Section 6661(a)
Section 6661(a) imposes an addition to tax on a substantial
understatement of income tax. For corporations, an
understatement is substantial where it exceeds the greater of 10
percent of the tax required to be shown on the return or $10,000.
Sec. 6661(b)(1)(A) and (B). The section 6661 addition to tax is
not applicable, however, if there was substantial authority for
the taxpayer's treatment of the items in issue or if relevant
facts relating to the tax treatment were disclosed on the return.
Sec. 6661(b)(2)(B)(i) and (ii). Petitioners bear the burden of
disproving respondent's determination of an addition to tax
pursuant to section 6661. Rule 142(a).
Petitioners have not presented any authority to support
their treatment of the items at issue other than the cases that
we have distinguished, supra pp. 85-92. There was no disclosure
of the relevant facts on a return. Consequently, we sustain
respondent's determination of an addition to tax pursuant to
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