Clinton N. and Naomi K. Bohannon - Page 27

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            imposed by section 6662(a).  Rule 142(a); Tweeddale v.                                      
            Commissioner, 92 T.C. 501, 506 (1989).                                                      
                  Petitioners argue that they are not liable for the addition                           
            to tax under section 6661(a) and the accuracy-related penalty                               
            under section 6662(d) because they did not understate their tax                             
            on their 1988 and 1989 returns.  We disagree for reasons given                              
            above.                                                                                      
                  Petitioners argue that section 6662 was first effective for                           
            tax years beginning after December 31, 1989.  We disagree.                                  
            Section 6662 applies to returns due after December 31, 1989.                                
            Omnibus Budget Reconciliation Act of 1989, Pub. L. 101-239, sec.                            
            7721(a), 103 Stat. 2106, 2395.  This includes petitioners' 1989                             
            return.                                                                                     
                  If a taxpayer has substantial authority for the                                       
            tax treatment of any item on the return, the understatement                                 
            is reduced by the amount attributable to it.  Sec.                                          
            6661(b)(2)(B)(i).  The amount of the understatement is reduced                              
            for any item adequately disclosed on the taxpayer's return or in                            
            a statement attached to the return.  Sec. 6661(b)(2)(B)(ii).  The                           
            accuracy-related penalty does not apply to any part of an                                   
            underpayment for which there was reasonable cause and with                                  
            respect to which the taxpayer acted in good faith.  Sec. 6664(c).                           
            Petitioners do not contend that these exceptions apply here.  We                            
            conclude that petitioners are liable for the section 6661(a)                                






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