Anthony G. and Shirley A. Olbres - Page 60

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               Additions to Tax Under Section 6661(a)                                 
               Respondent determined that petitioners are liable for the              
          addition to tax under section 6661(a) for each of the years at              
          issue.  Petitioners presented no evidence and make no argument              
          about those determinations except for their contention regarding            
          the claimed 1988 computational error, which we have sustained.              
               Based on the record before us, we find that petitioners have           
          failed to prove that they are not liable for the addition to tax            
          under section 6661(a) for 1986, 1987, and 1988 except to the                
          extent of the portion of the understatement of income tax for               
          1988 that is attributable to the 1988 computational error.                  
          Accordingly, we sustain respondent's determinations under section           
          6661(a) for those years except to that extent.                              
               To reflect the foregoing,                                              


                                                  Decision will be entered            
                                             under Rule 155.                          


















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