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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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