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the burden of proving that respondent's determination is
incorrect. See Rule 142(a).
Petitioner failed to address this issue in his post-
trial briefs and has not shown any reason why he is not
liable for the addition. Accordingly, we sustain
respondent's imposition of the addition to tax for
substantial understatement of liability under section 6661.
Period of Limitations
Petitioner maintains that the period of limitations
on assessment and collection with respect to his income
tax for 1983 expired before respondent issued the subject
notice of deficiency. Section 6501(a) generally imposes a
3-year period of limitations on assessment and collection
of tax. Section 6501(a) provides as follows in this
regard:
SEC. 6501(a). General Rule.--Except as
otherwise provided in this section, the amount
of any tax imposed by this title shall be
assessed within 3 years after the return was
filed (whether or not such return was filed on
or after the date prescribed) * * * and no
proceeding in court without assessment for the
collection of such tax shall be begun after the
expiration of such period.
There is an exception to this 3-year period in the
case of a "false or fraudulent return with the intent to
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