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required to be shown or (2) $5,000. The understatement is
reduced to the extent that the taxpayer has (1) adequately
disclosed his or her position, or (2) has substantial authority
for the tax treatment of an item. Sec. 6661; sec. 1.6661-6(a),
Income Tax Regs.
Petitioner has averred no facts in support of his assignment
that respondent erred in determining an addition to tax under
section 6661. Moreover, on brief, petitioner makes no argument
disputing respondent's section 6661 determinations except:
“Petitioner believes that the understatement penalty will not
apply when the understatement amount is recalculated.” Because
of concessions and settled issues, we cannot determine whether
petitioner’s understatements are substantial. We sustain
respondent’s determinations of additions to tax under section
6661 to the extent that petitioner’s understatements are
substantial. For no year has petitioner proven that he
(1) adequately disclosed his position or (2) has substantial
authority for the tax treatment of an item.
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011