- 30 - 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.Page: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30
Last modified: May 25, 2011