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return or (2) disclosed the understatement on its return for that
year. We agree with respondent.
Petitioners did not present any evidence at trial which
would prove that Toraya had reasonable cause for the
understatement or that it acted in good faith in omitting the
income from its 1988 return or in overstating its deductions.
Rule 142(a); Tweeddale v. Commissioner, 92 T.C. at 506.
Accordingly, we sustain respondent's determination as to the
addition to tax under section 6661 for 1988.
To reflect the foregoing and the concessions of the parties,
Decisions will be entered
under Rule 155.
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