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required to be shown on the return or $5,000 ($10,000 in the case
of a corporation other than an S corporation). Sec. 6661(b)(1).
An understatement is reduced 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).
Petitioners did not adequately disclose the amounts leading
to the understatements on their returns. They also have not
cited any relevant authority to support any part of the
understatements. We sustain respondent's determinations on this
issue.
To reflect the foregoing,
Decisions will be entered
under Rule 155.
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