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[income tax laws]" and disregard "includes any careless,
reckless, or intentional disregard."
As a general rule, the Commissioner's determinations are
presumed correct, and the taxpayer bears the burden of proving
otherwise. Rule 142(a); Welch v. Helvering, supra. Petitioner
did not address this penalty at trial or on brief and has
therefore failed to meet his burden with respect to this issue.
Accordingly, the penalty under section 6662 is sustained.
For the foregoing reasons, and to take account of a
concession,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011