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between the amount required to be shown on the return and the
amount actually shown on the return. Sec. 6662(d)(2)(A). The
understatement is reduced, however, to the extent it is (1) based
on substantial authority or (2) adequately disclosed in the
return or a statement attached to the return. Sec.
6662(d)(2)(B)(i) and (ii). Neither exception is present here.
Therefore, if the recomputed deficiency under Rule 155 satisfies
the statutory percentage or amount, petitioner will be liable for
the addition to tax under section 6662(a).
To reflect the foregoing,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011