Willie Thomas - Page 15

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          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.                          












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