- 20 - relates to the $20,306 listed as owed on their original return. Petitioners further stipulated that they are liable for an addition to tax pursuant to section 6651(a)(1) for 1990 insofar as it relates to their basis in their Price Co. stock if we found that the shares transferred to petitioners by Drachman on October 30 and December 10, 1987, were not bona fide loans. We have so found. Petitioners did not stipulate their liability for an addition to tax pursuant to section 6651(a)(1) insofar as it relates to the additional tax liability acknowledged on their amended return filed April 20, 1992. The Commissioner's determinations are presumed correct, and the taxpayer bears the burden of proving otherwise. Rule 142(a); Welch v. Helvering, 290 U.S. at 115. Some of petitioners' liability for additions to tax pursuant to section 6651(a)(1) for 1990 has been stipulated, and petitioners have failed to meet their burden as to the other liability. Accordingly, respondent's addition to tax pursuant to section 6651(a)(1) is sustained. For the foregoing reasons, Decision will be entered under Rule 155.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20
Last modified: May 25, 2011