54 Former section 6661(a) provides for an addition to tax equal to 25 percent of the amount attributable to a substantial understatement of income tax. An understatement is substantial if it exceeds the greater of 10 percent of the tax required to be shown on the return or $10,000 in the case of a corporation. Sec. 6661(b)(1)(A) and (B). An understatement of income tax occurs if the tax actually shown on the return is less than the amount required to be shown on the return. Sec. 6661(b)(2); Woods v. Commissioner, 91 T.C. 88, 95 (1988). Petitioners bear the burden of proving that respondent's determination is erroneous. Rule 142(a); Conti v. Commissioner, 39 F.3d 658, 664 (6th Cir. 1994), affg. and remanding 99 T.C. 370 (1992). Alondra reported total tax due for Alondra's fiscal 1987 of $222,879. In computing this tax, Alondra claimed deductions for rent, management fees, and wages that respondent disallowed. In light of our findings on these issues, Alondra's understatement of tax exceeds the threshold established by section 6661. Thus, Alondra made a substantial understatement within the meaning of section 6661(b). Petitioners argue, as they do for the negligence additions to tax, that they reasonably relied on competent professional advice. We reject this argument here as well, just as we do for the negligence additions to tax, and for the same reasons. An understatement will be reduced to the extent that it is: (1) Based on substantial authority or (2) adequately disclosed inPage: Previous 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 Next
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