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Because, however, the erroneous mortgage interest expense
deduction is not attributable to Mr. Makalintal, the innocent
spouse provision of section 6013(e)(1) does not immunize
petitioner from liability for the additions to tax for 1988 that
are attributable to that adjustment. Petitioner has not provided
any evidence as to the basis for this claimed deduction, and
petitioner has not provided any substantial authority or
reasonable cause for claiming this deduction.
We sustain for 1988 the portion of the negligence addition
to tax under section 6653(a)(1)(A) and (B) and the portion of the
substantial understatement addition to tax under section 6661(a)
that are attributable to the understatement in tax for 1988 that
relates to the claimed mortgage interest expense deduction.
Decisions will be entered
under Rule 155.
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