Shigenori Kudo and Motomi Kudo, et al. - Page 84

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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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