- 28 - careful consideration of the evidence, including the selling price of the other South Wood condominiums and petitioner’s sale price of his own South Wood Condominium around the time for filing his 1988 return, should have alerted him, as an accountant, to the appropriate values for the condominium units distributed. See deRochemont v. Commissioner, T.C. Memo. 1991- 600. We sustain respondent’s determination that petitioner was negligent with respect to the underpayment. B. Section 6661 substantial understatement addition Respondent determined that petitioner is liable for an addition to tax under section 6661 for substantial understatement. This addition applies when the understatement of income tax exceeds the greater of (1) 10 percent of the tax required to be shown on the return for the taxable year, or (2) $5,000. Sec. 6661(b)(1). The understatement for purposes of this addition is 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). Petitioner made no disclosure of the distribution on his individual return for 1988 and made no argument against imposition of this addition. Since the amount of petitioner’sPage: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 Next
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