- 66 - intended to conceal, mislead, or otherwise prevent the collection of Federal income tax. Additions to Tax Under Section 6661 Respondent determined that petitioners are liable for the addition to tax for substantial understatement of liability under section 6661. Section 6661 imposes an addition to tax of 25 percent of any underpayment attributable to a substantial understatement of income tax which is assessed after October 21, 1986. Pallottini v. Commissioner, 90 T.C. 498, 503 (1988). A substantial understatement is any understatement which exceeds the greater of 10 percent of the tax required to be shown on the return or $5,000. Sec. 6661(b)(1). Petitioners bear the burden of proving that respondent's determinations are incorrect. Rule 142(a). Petitioners failed to address this issue at trial or in their posttrial briefs. They have shown no reason why they are not liable for the addition to tax. Accordingly, we sustain respondent's determination that petitioners are liable for the addition to tax for substantial understate- ment of liability under section 6661. Innocent Spouse Relief Petitioners claim that Mrs. London is eligible to be relieved of liability for the tax deficiencies andPage: Previous 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67 68 69 70 Next
Last modified: May 25, 2011