- 36 - Petitioner has no tax or accounting background. She used a competent contractor to contemporaneously estimate the amount of damage to her home. She was reasonably careful in preparing her loss estimate, and she reasonably relied on her accountant to prepare her return. She gave her accountant all necessary information to prepare her return. She attached to Form 4684, Casualties and Thefts, a detailed inventory of her personal property loss and the $202,200 reduction in the value of her real property by the San Mateo County tax assessor's office. She hired a personal property appraiser to verify her estimates of her personal property loss. Petitioner made a reasonable attempt to figure the amount of her casualty loss. We hold that she was not negligent. 2. Substantial Understatement The next issue for decision is whether petitioner is liable for the addition to tax for substantial understatement of income tax under section 6661(a) for tax years 1985-87. Section 6661(a) provides for an addition to tax in the amount of 25 percent of the amount of any underpayment attributable to a substantial understatement of income tax. An understatement is the amount by which the correct tax exceeds the tax reported on the return. Sec. 6661(b)(2)(A). An understatement is substantial if it exceeds the greater of 10 percent of the tax required to be shown on the return or $5,000.Page: Previous 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 Next
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