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Petitioners bear the burden of proving that they
are not liable for the additions to tax and penalty as
determined by respondent. Rule 142(a); Axlerod v.
Commissioner, 56 T.C. 248, 258-259 (1971). Petitioners
did not take issue with respondent's determination in their
pleadings or post-trial briefs and have presented nothing
to show that respondent's determinations are erroneous.
Accordingly, we sustain respondent's determination and find
that petitioners are liable for the additions to tax under
sections 6653(a) and 6661, and for the penalty under
section 6662.
In light of the foregoing, and reflecting concessions,
An appropriate order will
be issued denying respondent's
motion for leave to file
amendments to answers and to
conform the pleadings to the
proof and decisions will be
entered under Rule 155.
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