- 84 - 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.Page: Previous 65 66 67 68 69 70 71 72 73 74 75 76 77 78 79 80 81 82 83 84
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