Don C. and Judy Montgomery - Page 39

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             to be shown for the taxable year or $5,000.  Secs.                       
             6661(b)(1)(A), 6662(d)(1)(A).  In determining whether there              
             is a substantial understatement of liability, the amount                 
             of an understatement is reduced by any portion attributable              
             to the tax treatment of an item for which the taxpayer had               
             substantial authority, and by any item with respect to                   
             which the relevant facts affecting the taxpayer's treat-                 
             ment are adequately disclosed in the return or in a                      
             statement attached to the return.  Secs. 6661(b)(2)(B),                  
             6662(d)(2)(B).                                                           
                  Petitioners bear the burden of proving that                         
             respondent's imposition of an addition to tax under section              
             6661 or penalty under section 6662 is erroneous.  See Rule               
             142(a); Luman v. Commissioner, 79 T.C. 846, 860 (1982).                  
             Petitioners also bear the burden of proving that they had                
             substantial authority for omitting an item from their                    
             return.  See Tippin v. Commissioner, 104 T.C. 518, 535                   
             (1995).                                                                  
                  We find that petitioners have failed to satisfy their               
             burden of proving that respondent's imposition of the                    
             addition to tax under section 6661 and penalty under                     
             section 6662 is erroneous in this case.  Petitioners                     
             offered no authority for their position that the items                   







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