Alondra Industries, Limited, d.b.a. Accent Insulation Company and Subsidiaries, et al. - Page 54

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               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 in           





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