- 21 - understated his gross income or blatantly claimed deductions that he knew or should have known were for personal expenses and therefore unallowable. Petitioner has the burden of proof on the additions to tax and penalty issues, which he has failed to carry. Bixby v. Commissioner, 58 T.C. 757 (1972); see Grzegorzewski v. Commissioner, T.C. Memo. 1995-49. Respondent's determinations are therefore sustained. Respondent has conceded the substantial understatement penalty under section 6661 for 1988. Respondent determined a 10-percent penalty under section 72(t) in the amount of $60 for a premature distribution made in 1988 from petitioner's Keogh account, a qualified retirement plan. Petitioner does not address this issue in either of his briefs, and it is therefore deemed conceded. To reflect the above, Decision will be entered under Rule 155.Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21
Last modified: May 25, 2011