- 18 -
was not due to negligence.6 Petitioners simply argue that they
are entitled to section 1034 treatment and, accordingly, are not
negligent. That argument only addresses the negligence issue for
1988. Regarding respondent's 1987 negligence determination,
petitioners have failed to carry their burden inasmuch as they
did not present any evidence relevant to that determination.
We hold petitioners liable for additions to tax for
negligence for 1987 and 1988, as determined by respondent, to the
extent of any underpayment decided for those years.
To reflect the foregoing and concessions of the parties,
Decision will be entered
under Rule 155.
6 The 1987 income tax deficiency was based on seven income
adjustments and a self-employment tax adjustment. Of the seven
adjustments, respondent appears to have conceded one and the
parties settled the others.
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