- 25 -
neither exceeded 10 percent of the amount required to be shown,
nor was over $5,000. Hence, the understatement was not
substantial as defined by section 6662.
Petitioners' Claim for Refund
The parties agree that the notice of deficiency contains an
error in the calculation of petitioners' basis in Resthaven.
They have further agreed that petitioners' basis in Resthaven
should not be reduced by the amount of dividend distributions.
The parties are to reflect their agreement in the Rule 155
computation.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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