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authority that will be considered in determining whether
substantial authority exists. The authority upon which
petitioner relies, i.e., the court award and the Lipsig firm's
treatment, are not among those that will be considered.
Furthermore, there is no evidence that petitioner made any
disclosure of the item on his 1987 tax return. Petitioner has
thus failed to prove that he is not subject to the section 6661
addition to tax. Accordingly, we sustain respondent's section
6661 addition to tax.
An order denying petitioner’s
oral motion to shift the burden of proof
will be issued.
An order denying petitioner’s
oral motion to dismiss for lack of
jurisdiction will be issued, and
decision will be entered for respondent
in docket No. 21777-93.
Decisions will be entered for
petitioner in docket Nos. 5780-92 and
592-94.
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