- 38 - negligence is erroneous. See Rule 142(a); Hitchins v. Commissioner, supra. Petitioners have not introduced any evidence or made any argument that they acted with reasonable care in reporting their income for 1988. Consequently, we find that petitioners have failed to satisfy their burden of proving that respondent's determination of negligence is erroneous. In addition to negligence, respondent determined that petitioners are liable for the addition to tax for sub- stantial understatement of income tax, as prescribed by section 6661 with respect to their 1988 return. As in effect during 1988, section 6661 imposed an addition to tax equal to 25 percent of any underpayment of income tax attributable to a substantial understatement of liability. Sec. 6661(a). Respondent also determined that petitioners are liable for the accuracy-related penalty prescribed by section 6662 with respect to their 1989 return. Section 6662 imposes a penalty equal to 20 percent of any under- payment of income tax attributable to a substantial understatement of liability. Sec. 6662(a). Both sections 6661 and 6662 define a "substantial understatement" as an understatement of tax liability equal to the greater of 10 percent of the tax requiredPage: Previous 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 Next
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