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understatements should be reduced under section 6661(b)(2)(B) or
that respondent should have waived all or any part of the
additions to tax under section 6661(c).23 We hold that NITCO is
liable for additions to tax under section 6661 for 1987 and 1988
and that the Mussmans are liable for an addition to tax under
section 6661 for 1988.
Decisions will be entered
under Rule 155.
23On brief, petitioners make the vague argument that they
should not be held liable for the sec. 6661 additions to tax,
because "the substantial understatement penalty is computational,
and thus may not apply; if it does, the penalty is inappropriate
because reasonable cause can be found for the understatement."
However, "reasonable cause", standing alone, is not a sufficient
basis for avoiding liability with respect to the sec. 6661
addition. See H. Conf. Rept. 97-760 at 575 (1982), 1982-2 C.B.
600, 650. At any rate, petitioners have failed to establish:
(1) There was substantial authority for their return positions or
reasonable disclosure on their returns; or (2) respondent should
have waived all or part of the additions. Rule 142(a).
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