18
addition to tax is presumed correct, and petitioner must prove
otherwise. Rule 142(a); Hall v. Commissioner, 729 F.2d 632, 635
(9th Cir. 1984), affg. T.C. Memo. 1982-337; Bixby v.
Commissioner, supra at 791-792.
Petitioner makes no argument with regard to substantial
authority or adequate disclosure, and we find that no such
argument exists. If recomputation of petitioner's tax liability
reflects a substantial understatement, petitioner is liable for
the addition to tax.
To reflect the foregoing and the concessions by the parties,
Decision will be entered
under Rule 155.
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