Bruno and Francesca Tabbi - Page 47

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          6661(a) provides for an addition to tax in the amount of 25                 
          percent of the amount of any underpayment attributable to a                 
          substantial understatement of income tax.                                   
               An understatement is the amount by which the correct tax               
          exceeds the tax reported on the return.  Sec. 6661(b)(2)(A).  An            
          understatement is substantial if it exceeds the greater of 10               
          percent of the tax required to be shown on the return or $5,000.            
          Sec. 6661(b)(1)(A).  Petitioners bear the burden of proving that            
          the addition to tax under section 6661 does not apply.  Rule                
          142(a); Tweeddale v. Commissioner, 92 T.C. 501, 506 (1989).                 
               If a taxpayer has substantial authority for the                        
          tax treatment of any item on the return, the understatement                 
          is reduced by the amount attributable to it.  Sec.                          
          6661(b)(2)(B)(i).  Similarly, the amount of the 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).  Neither of these exceptions applies                
          here.                                                                       
               Petitioners argue that they did not substantially understate           
          their income for 1987 if all deductions and economic losses are             
          allowed for that year.  They also argue that there was no                   
          substantial understatement for 1988 because the tax liability               
          for 1988 is not substantial.                                                
               Petitioners omitted large amounts of income from their                 
          1987 and 1988 joint returns, which caused substantial                       




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