- 15 - deficiency relating to self-employment tax is not attributable to fraud and that the additions to tax for fraud, pursuant to section 6653(b)(2), must be reduced accordingly. IV. Additions to Tax for Substantial Understatements Respondent determined that petitioner is liable, pursuant to section 6661(a), for additions to tax for substantial understatements of income tax. The addition to tax is equal to 25 percent of the amount of each underpayment of tax attributable to a substantial understatement. Petitioner bears the burden of proving that respondent's determination is erroneous. Rule 142(a); Cluck v. Commissioner, 105 T.C. 324, 340 (1995). Petitioner did not dispute his liability for the additions to tax provided by section 6661(a). Therefore, petitioner has failed to carry his burden of proof and is liable for the additions to tax. We have considered the other arguments raised by the parties and find that they are without merit. To reflect the foregoing, Decision will be entered under Rule 155.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15
Last modified: May 25, 2011