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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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