- -33 required to be shown on the return or $5,000. Sec. 6661(b)(1)(A). If a taxpayer has substantial authority for his tax treatment of any item on the return, the understatement is reduced by the amount attributable thereto. Sec. 6661(b)(2)(B)(i). Similarly, the amount of understatement is reduced for any item adequately disclosed either on the taxpayer's return or in a statement attached to the return. Sec. 6661(b)(2)(B)(ii). Section 6662(a), applicable for 1989, imposes an addition to tax of 20 percent of the underpayment of tax if any portion of the underpayment is due to a substantial understatement of income tax. Sec. 6662(b)(2). "Understatement" is defined as the excess of (1) the amount of the tax required to be shown on the return for the taxable year, over (2) the amount of the tax imposed that is shown on the return. Sec. 6662(d)(2)(A). Except for items attributable to tax shelters, an understatement is reduced to the extent that it is based on an item which is adequately disclosed in the return or in a statement attached to the return or for which there is substantial authority for the taxpayer's position. Sec. 6662(d)(2)(B). A substantial understatement of income tax occurs where the amount of the understatement exceeds the greater of (1) 10 percent of the tax required to be shown on the return or (2) $5,000. Sec. 6662(d)(1).Page: Previous 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 Next
Last modified: May 25, 2011