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1985, section 6661(a) imposed an addition to tax of 25 percent of
the amount of any underpayment attributable to a substantial
understatement of income tax. Petitioner bears the burden of
proving that he is not liable for the addition to tax under
section 6661. Rule 142(a).
Petitioner offered no evidence or argument that he is not
liable for the addition to tax under section 6661(a) for 1985.
We conclude that petitioner is liable for the section 6661(a)
addition to tax for 1985.
To reflect the foregoing,
Decision will be
entered under Rule 155.
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Last modified: May 25, 2011