Michael London - Page 66

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             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 and                       





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