Jerome J. and Beatrice A. Mack - Page 33

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          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).                                            






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