Paul A. Rendina and Janet Mae Rendina - Page 28

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          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’s              







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