Ronald E. Reed - Page 11

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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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