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understatement. An understatement is "substantial" when the
understatement for the taxable year exceeds the greater of
(1) 10 percent of the tax required to be shown or (2) $5,000.
The understatement is reduced to the extent that the taxpayer
has (1) adequately disclosed his or her position, or (2) has
substantial authority for the tax treatment of an item. Sec.
6661; sec. 1.6661-6(a), Income Tax Regs. Petitioners bear the
burden of showing that they are not subject to the addition to
tax determined by respondent. Rule 142(a).
Petitioners have averred no facts in support of their
assignment that respondent erred in determining an addition to
tax under section 6661. Moreover, on brief, petitioners make no
argument disputing respondent's section 6661 determinations. We
assume that petitioners have abandoned their claims of error with
regard to section 6661. On that basis, respondent's
determination of additions to tax under section 6661 are
sustained.
Decisions will be entered
for respondent.
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