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July 11, 1988,2 respondent determined deficiencies in
petitioners' Federal income taxes, in the amounts listed below:
Additions to Tax and Increased Interest
Sec. Sec. Sec. Sec. Sec. Sec.
Year Deficiency 6621(c) 6653(a) 6653(a)(1) 6653(a)(2) 6659 6661
1979 $7,010 1 $350.50 -- -- $2,103 --
1980 11,021 1 551.00 -- -- 3,306 --
1981 -- 1 -- $4.55 2 -- --
--218
1982 -- 1 -- 256.00 2 $2,753
1To be determined.
2Fifty percent of the interest due on the deficiency.
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure. The notice of deficiency for the 1982 tax year
determined petitioners had a zero deficiency but were liable for
additions to tax pursuant to sections 6653, 6659, and 6661.
Respondent contends that the zero deficiency occurred as a result
of a clerical error in the Schedule of Adjustments, which was
attached to the notice of deficiency for the 1982 tax year. In
an Amendment to Answer, filed April 12, 1995 (Amendment to
Answer), respondent corrected the error on the statutory notice
of deficiency and stated that the correct deficiency is $29,913.
Respondent contends that she does not bear the burden of proof as
2Respondent issued two notices of deficiency to petitioners.
Both notices are dated July 11, 1988. In the first notice of
deficiency, respondent determined deficiencies and additions to
tax in petitioners' Federal income taxes for the taxable years
1979, 1980, and 1981. In the second notice of deficiency,
respondent determined deficiencies and additions to tax in
petitioners' Federal income taxes for the taxable year 1982.
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