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Petitioners allege that this stipulated fair rental value of
the parsonages already includes an amount reflecting the amounts
petitioner either designated or received in cash relating to
their utility and other household expenses. Accordingly,
petitioners claim that the adjustment that respondent made with
respect to the parsonages and related items should now be reduced
by the amounts that petitioner either designated or received in
cash relating to their utility and other household expenses.
Petitioners bear the burden of proving that respondent’s
adjustments are incorrect. Rule 142(a); Welch v. Helvering, 290
U.S. 111 (1933).
Petitioners have not proven that the stipulated fair rental
value of the parsonages already includes amounts petitioner
designated or received in cash relating to the utility and other
household expenses of the parsonages. In calculating
petitioner’s self-employment income, no reduction is to be made
to respondent’s adjustments relating to petitioner’s self-
employment tax liability.
Addition to Tax
Section 6651(a)(1) provides for an addition to tax for
failure to timely file a Federal income tax return. The addition
to tax is 5 percent of the amount required to be shown as tax on
the return for every month the return is late, but not exceeding
25 percent. This addition to tax will not be imposed if it is
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