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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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Last modified: May 25, 2011