Morton Zuckerman - Page 11

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          liability for 1987 without regard to items attributable to                  
          Mrs. Zuckerman and using rates applicable to married persons                
          filing separately.  The deficiency and additions to tax                     
          recomputed in this manner are higher than those set forth in the            
          notice of deficiency:                                                       
                            Additions to Tax                                          
          Sec.          Sec.             Sec.        Sec.                             
          Year  Deficiency   6651(a)(1)   6653(a)(1)(A)   6653(a)(1)(B)    6661       
          1987   $31,702      $7,950         $1,590                1                  
          $7,926                                                                      
               1Fifty percent of the interest due on $31,702.                         


          The increase in the deficiency results in large part from                   
          respondent's assumption that the $18,423 of reported wage and               
          gambling income attributable to Mrs. Zuckerman was not the source           
          of any of the total $84,653 of deposits to petitioner's bank                
          accounts during the year, from which respondent concluded that              
          petitioner had $18,423 more unreported income than she had                  
          originally determined.  In her amended answer, respondent did not           
          recompute the deficiency and additions to tax for the 1986                  
          taxable year.                                                               
                                       OPINION                                        
               Respondent's determinations in the notice of deficiency are            
          presumed to be correct, and petitioner has the burden of proving            
          otherwise.  Rule 142(a); Welch v. Helvering, 290 U.S. 111, 115              
          (1933).  However, respondent has the burden of proving the                  





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