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as to the addition to tax under section 6661(a) is erroneous.
Rule 142(a).
An understatement is the difference between the amount
required to be shown on the return and the amount actually shown
on the return. Sec. 6661(b)(2); Tweeddale v. Commissioner, 92
T.C. 501 (1989); Woods v. Commissioner, 91 T.C. 88 (1988). An
understatement is substantial if it exceeds the greater of $5,000
or 10 percent of the amount required to be shown on the return.
Sec. 6661(b)(1). The understatement is reduced, however, to the
extent it is: (1) Based on substantial authority, or (2)
adequately disclosed in the return or in a statement attached to
the return. Sec. 6661(b)(2)(B).
Petitioner made no arguments and presented no evidence
regarding the substantial understatement additions to tax.
Therefore, petitioner has failed to carry her burden of proof as
to those items. Accordingly, if the recomputed deficiency under
Rule 155 attributable to those items satisfies the statutory
percentage or amount, petitioner will be liable for such
additions to tax.
To reflect the foregoing opinion and the concessions of the
parties,
Decision will be entered
under Rule 155.
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