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6661 additions. Accordingly, as we noted in Brown v.
Commissioner, T.C. Memo. 1992-15, "we cannot find that respondent
abused * * *[her] discretion when petitioner never requested
respondent to exercise it." See also McCoy Enterprises, Inc. v.
Commissioner, T.C. Memo. 1992-693 (same), affd. 58 F.3d 557 (10th
Cir. 1995) (affg. on precisely that point).
On the premises stated, the section 6661 additions to tax
determined by respondent are sustained.
B. Section 6662
Respondent has determined accuracy related penalties under
section 6662 for 1989 and 1990. Section 6662(a) provides for an
accuracy related penalty in the amount of 20 percent of the
portion of any underpayment of tax liability attributable to,
among other things, any substantial understatement of income tax.
Sec. 6662(b)(2). A substantial understatement is defined as an
understatement which exceeds the greater of 10 percent of the tax
required to be shown on the return for the year or $5,000. Sec.
6662(d)(1)(A). The amount of the understatement, however, is
reduced by amounts attributable to items for which (1) there
existed substantial authority for the taxpayer's position, or
(2) where the taxpayer disclosed relevant facts concerning the
items with his tax return. Sec. 6662(d)(2)(B). No penalty is
imposed with respect to any portion of an underpayment if the
taxpayer can show that there was a reasonable cause for such
portion and that the taxpayer acted in good faith with respect to
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