Reginald Maurice Wise and Shannon Rae Wise - Page 32

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          Respondent has authority to waive this addition to tax, if the               
          taxpayer shows there was reasonable cause for the understatement             
          and the taxpayer acted in good faith.  Sec. 6661(c).                         
               Petitioners bear the burden of proving that imposition of               
          the addition to tax under section 6661 is erroneous.  Rule                   
          142(a); Tweeddale v. Commissioner, 92 T.C. 501, 506 (1989).                  
                    a.   The Wises                                                     
               The Wises substantially understated their income tax for                
          1988.  Although distinguishable on its facts, Selfe v. United                
          States, 778 F.2d 769 (11th Cir. 1985), is substantial authority              
          for petitioners' claim to increase their bases because Wise and              
          Eicher guaranteed the HMC loan.  However, they have not shown                
          that they (1) had other substantial authority for the other                  
          positions taken on their tax return, (2) adequately disclosed                
          their position on the tax return or in a statement attached to               
          the tax return, (3) had reasonable cause for the understatement,             
          or (4) acted in good faith.  The Wises have failed to carry their            
          burden of proof.  We agree with respondent on this issue except              
          for petitioners' increased basis for the HMC loan.                           
                    b.   Eicher                                                        
               Eicher may reduce the amount of the understatement because              
          of his reliance on Selfe v. United States, supra.  To the extent             
          Eicher has otherwise substantially understated his income tax for            








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