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6661 addition to tax but has not averred any facts in support of
that assignment. We assume that petitioner relies on our finding
no (or reduced) deficiencies to support his assignment of error.
Petitioner bears the burden of proof. Rule 142(a). We do not
find any reduced deficiencies (except as necessary to take into
account one adjustment agreed to by the parties); therefore,
petitioner has failed to carry his burden of proof, and we
sustain the determination of additions to tax under section 6661,
modified to take account of the agreement of the parties.
IV. Additions to Tax for Fraud
Respondent also determined additions to tax for fraud under
section 6653(b)(1) and (2) for 1985 and under section
6653(b)(1)(A) and (B) for 1986 and 1987. For 1985, section
6653(b)(1) imposes an addition to tax equal to 50 percent of any
underpayment in tax if any part of the underpayment is due to
fraud; section 6653(b)(2) imposes a separate addition to tax,
equal to 50 percent of the interest payable under section 6601,
determined on the portion of the underpayment attributable to
fraud. For 1986 and 1987, section 6653(b)(1)(A) imposes an
addition to tax equal to 75 percent of any underpayment in tax if
any part of the underpayment is due to fraud; section
6653(b)(1)(B) imposes a separate addition to tax, equal to
50 percent of the interest payable under section 6601, determined
on the portion of the underpayment attributable to fraud.
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