Chong-Kak and Sang-Ok Lee - Page 30

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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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