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Issue 9. Addition to Tax Under Section 6661
Respondent determined an addition to tax under section 6661
for the years 1982, 1983, 1985, and 1986.
For returns due after December 31, 1982 (but before January
1, 1990), section 6661 provides for an addition to tax equal to
25 percent of the amount of any underpayment attributable to a
substantial understatement. An understatement is "substantial"
if it exceeds the greater of (1) 10 percent of the tax required
to be shown on the return or (2) $5,000. The understatement is
reduced to the extent that the taxpayer (1) has adequately
disclosed his or her position, or (2) has substantial authority
for the tax treatment of an item. See sec. 6661; sec. 1.6661-
6(a), Income Tax Regs. Petitioner again bears the burden of
showing that he is not subject to the addition to tax determined
by respondent. See Rule 142(a); Cochrane v. Commissioner, 107
T.C. 18, 29 (1996).
Petitioner has presented no evidence to show that respondent
erroneously determined the addition to tax under section 6661.
Accordingly, we hold that petitioner is liable for the addition
to tax under section 6661 for 1982, 1983, 1985, and 1986.
Issue 10. Addition to Tax Under Section 6651(a)(1)
Respondent determined an addition to tax under section
6651(a)(1) for failure to file a timely return for 1992.
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