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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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