Douglas E. Kahle - Page 11

            proof, which is not lessened in a fully stipulated case.  Rule                            
            142(a); Tippin v. Commissioner, 104 T.C. 518, 533 (1995);                                 
            Borchers v. Commissioner, 95 T.C. 82, 91 (1990), affd. 943 F.2d                           
            22 (8th Cir. 1991).  Petitioner has conceded that the returns for                         
            both years at issue were filed delinquently and has offered no                            
            other evidence on the issues of additions to tax and penalties,                           
            which he did not address in his brief.  Accordingly, we sustain                           
            respondent's determinations.                                                              
                  To reflect the foregoing, and concessions of the parties,                           
                                                      Decision will be                                
                                                 entered under Rule 155.                              





























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