- -34
We conclude that petitioners did not have substantial
authority for their position with respect to the items we have
determined against them and the items they have conceded, nor did
they adequately disclose on their return facts that would have
revealed the controversy with respect to those items. If, and to
the extent that the amount of understatement makes section 6661
or section 6662 applicable to petitioners, we hold for respondent
on this issue.
Decision will be
entered under Rule 155.
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