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of tax attributable to, among other things, any substantial
understatement of income tax. Sec. 6662(a), (b)(2). In the
notice of deficiency, respondent determined that the entire
underpayment of tax for the 1991 taxable year was due to a
substantial understatement of income tax. Petitioners bear the
burden of proving that respondent's determination is erroneous.
See Rule 142(a). In their briefs, petitioners simply assert that
there is no substantial understatement of income tax. On the
record before us, we find that respondent's determination of a
penalty under section 6662(a) is correct, except to the extent
that it relates to respondent's concessions regarding the
unexplained bank deposits discussed in supra section III.A.
V. Conclusion
Respondent's determinations of a deficiency in and penalty
on petitioners' Federal income tax for the 1991 taxable year are
sustained to the extent set forth in this report.
Decision will be entered
under Rule 155.
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