Estate of David J. Dickerson, Deceased, Dorothy Dickerson, Executor and Dorothy Dickerson, et al. - Page 26

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          expenses.”  Rule 142(a); Ronnen v. Commissioner, 90 T.C. 74, 102            
          (1988).  Based upon the lack of any evidence provided by                    
          petitioners, and taking into account their stipulations and                 
          admissions, we find that they have failed to carry their burden             
          of proof with respect to both the deductibility and the amount of           
          the claimed deductions.  Accordingly, we sustain respondent on              
          this issue.                                                                 
          Substantial Understatement Penalty--Michoff, Srs.                           
               Respondent determined additions to tax of $7,339 and $2,112            
          under section 6661 for the tax years 1986 and 1987, respectively,           
          for the Michoff, Srs.  Section 6661(a) imposes an addition to tax           
          of 25 percent of the amount of any underpayment attributable to a           
          substantial understatement of tax.  An understatement is the                
          difference between the amount required to be shown on the return            
          and the amount actually shown on the return and is substantial if           
          it exceeds the greater of (1) 10 percent of the tax required to             
          be shown on the return for a taxable year, or (2) $5,000.  Sec.             
          6661(b)(1) and (2)(A).  The understatement is reduced to the                
          extent that the taxpayer has (1) adequately disclosed his or her            
          position or (2) has substantial authority for the tax treatment             
          of an item.  Sec. 6661; sec. 1.6661-6(a), Income Tax Regs.                  
          Petitioners have the burden of proving they are not liable for              
          the addition to tax.  Rule 142(a).                                          
               The Michoff, Srs., contend that they should not be liable              
          for the substantial understatement penalty because their                    

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