- 60 - 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.Page: Previous 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60
Last modified: May 25, 2011