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response to the SCB summons (December 16, 1998). That is less
than the 156 days remaining in the 3-year period of limitations.
Thus, the notice of deficiency of May 12, 1999, was timely
mailed.
D. Substantial Understatement Under Section 6661
Respondent determined that petitioner is liable for the
addition to tax under section 6661 for substantial understatement
of income tax for 1987 and 1988 and that TCM is liable for the
addition to tax under section 6661 for 1987. Petitioner bears
the burden of proving that respondent erred in imposing the
addition to tax under section 6661. Rule 142(a)(1).
Petitioners contend that they did not substantially
understate their income tax for 1987 and 1988. Petitioners raise
no other defense. We conclude that petitioners are liable for
the section 6661(a) addition to tax.
To reflect the foregoing,
Decisions will be entered
under Rule 155.
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