Northwestern Indiana Telephone Company - Page 92

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            1988 and (2) under section 6662 for 1989.  The section 6662                                
            addition applies with respect to the entire underpayment for                               
            1989.                                                                                      

            Section 6661 Additions for Substantial Understatement                                      

                  In the notice of deficiency issued to NITCO, respondent                              
            determined that NITCO was liable for additions to tax for                                  
            substantial understatement of income tax liability under section                           
            6661 for 1987 and 1988.  In the notice of deficiency issued to                             
            the Mussmans, respondent determined the Mussmans were liable for                           
            an addition to tax for substantial understatement under section                            
            6661 for 1988.                                                                             
                  Section 6661 provides for an addition to tax for substantial                         
            understatement of income tax equal to 25 percent of the amount of                          
            the underpayment attributable to such understatement for the                               
            taxable year.  To be considered substantial, the understatement                            
            must exceed the greater of $5,000 ($10,000 in the case of a                                
            corporation like NITCO) or 10 percent of the tax required to be                            
            shown on the return.  Sec. 6661(b)(1).  The amount of the                                  
            understatement is reduced by the portion of the understatement                             
            attributable to any nontax shelter item for which there is either                          
            substantial authority for the taxpayer's return position or                                
            adequate disclosure on the return.  Sec. 6661(b)(2)(B).                                    
                  NITCO understated its tax for 1987 and 1988; the Mussmans                            
            understated their tax for 1988.  These respective understatements                          
            were substantial.  Petitioners have not asserted that the                                  



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