Clinton N. and Naomi K. Bohannon - Page 26

                                                  26                                                    
                  Petitioners argue that they established that the general                              
            business credit arose from Bob Wade Ford's purchase of assets                               
            qualifying for the investment tax credit.  We disagree;                                     
            petitioners have not identified the property for which the credit                           
            was claimed or established that the property was qualified                                  
            property.  Sec. 38(a).  We sustain respondent on this issue.                                
            F.    Substantial Understatement of Income Tax                                              
                  The next issue for decision is whether petitioners are                                
            liable for the addition to tax under section 6661(a) for 1988 and                           
            the accuracy-related penalty under section 6662(d) for 1989 for                             
            substantial understatement of income tax.  Section 6661(a)                                  
            imposes an addition to tax equal to 25 percent of the amount of                             
            any underpayment attributable to a substantial understatement of                            
            income tax.  The accuracy-related penalty equals 20 percent of                              
            any part of an underpayment attributable to a substantial                                   
            understatement of income tax.  Sec. 6662(a) and (b)(2).                                     
                  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.                            
            Secs. 6661(b)(1)(A) and 6662(d)(1)(A).  Petitioners bear the                                
            burden of proving that they are not liable for the addition to                              
            tax under section 6661(a) and the accuracy-related penalty                                  








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