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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.
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