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in issue, it is unnecessary to consider whether he is liable for
additions to tax for negligence or delinquency for the 1985
through 1988 taxable years.
Regarding the 1989 taxable year, it is unnecessary to
consider the accuracy-related penalty under section 6662 because
we have found that petitioner is liable under section 6663(a).
With respect to the addition to tax for delinquency under
section 6651(a)(1) for the 1989 taxable year, that issue is not
preempted by our section 6663(a) finding. Petitioner's 1989
Federal income tax return was not filed until November 29, 1990.
Petitioner bears the burden of showing that respondent's
determination of the addition to tax for failure to timely file
is in error. Petitioner did not show that he obtained extensions
to file beyond the normal April 15, 1990, date or that he had
reasonable cause for filing beyond the required date.
Accordingly, petitioner is liable for the section 6651(a)(1)
addition for the 1989 taxable year.
Issue 7. Whether Petitioner Is Liable for the Substantial
Understatement Addition to Tax Under Section 6661 for 1985, 1986,
1987, or 1988
Section 6661 provides for a 25-percent addition to tax on
any substantial understatement. Pallottini v. Commissioner, 90
T.C. 498 (1988). A substantial understatement is one that
exceeds the greater of 10 percent of the tax required to be shown
on the return or $5,000. Sec. 6661(b)(1). The amount of an
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