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          sufficiently disclosed to his accountant his transactions with              
          Pecaris, and that petitioners reasonably relied on the way in               
          which their accountant treated the transaction on the joint                 
          return.                                                                     
               The characterization of the Mall transaction and partnership           
          allocation rules present complex legal issues, on which there can           
          be reasonable differences of opinion.  See Yelencsics v.                    
          Commissioner, 74 T.C. 1513, 1533 (1980); cf. Marcello v.                    
          Commissioner, 43 T.C. 168, 182 (1964), affd. and remanded in part           
          380 F.2d 499 (5th Cir. 1967).  Petitioner's beliefs that the                
          credits should not be included in the amount realized by Pecaris            
          or in the computation of its taxable gain and that there was a de           
          facto amendment to the Pecaris partnership agreement that                   
          relieved him from the allocation of gain that we hold him                   
          accountable for, were not completely untenable.  We reject                  
          respondent's imposition of the addition to tax for negligence.              
               B.  Section 6661 Substantial Understatement Addition                   
               Respondent determined that petitioners are liable for the              
          addition to tax for substantial understatement of income tax in             
          1988.  Income tax is substantially understated if the amount of             
          the understatement exceeds the greater of 10 percent of the tax             
          required to be shown on the return for the taxable year or                  
          $5,000.  Sec. 6661(b)(1)(A).  Section 6661(a) provides for an               
          addition to tax equal to 25 percent of the amount of any                    
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