- 28 - 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.Page: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Last modified: May 25, 2011