- 31 - 158, 173 (1978). We sustain respondent's determination that the corporate petitioner was negligent with respect to its underpayments. Addition to Tax under Section 6661 Respondent has determined an addition to tax under section 6661 for substantial understatement of tax for the corporate petitioner's taxable year ended September 30, 1988. This addition applies when the understatement of income tax of a corporate taxpayer exceeds the greater of (1) 10 percent of the tax required to be shown on the return for the taxable year, or (2) $10,000. Sec. 6661(b)(1). The understatement for purposes of this addition shall be reduced where there is substantial authority for the tax treatment of any item or if there was adequate disclosure, in or attached to the return, of the relevant facts affecting any item. Sec. 6661(b)(2)(B). The corporate petitioner has presented no argument in objection to this addition. Since the amount of the understatement for the taxable year ended September 30, 1988, is substantial, we sustain respondent's determination on this issue. The Suttons Rebate and Coupon Checks Respondent contends that Mr. Sutton diverted the proceeds of the cashed rebate and coupon checks from the corporate petitioner, thereby receiving constructive dividends. Petitioners allege thatPage: Previous 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 Next
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