Rene D. and Rosemary S. Valdes - Page 8

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          evidence that he had reasonable cause for the understatements or            
          that he acted in good faith.  Accordingly, we sustain                       
          respondent’s determinations.7                                               
               Reviewed and adopted as the report of the Small Tax Case               
               To reflect respondent’s concession,                                    
                                             Decision will be entered                 
                                        under Rule 155.                               

               7  Considering the amount of unreported income, respondent             
          has satisfied the burden of production with regard to the                   
          penalties.  See sec. 7491(c).                                               

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