John Boreta - Page 3

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               On audit, respondent disallowed the $813,462 claimed                   
          interest expense deduction.  Respondent also determined additions           
          to tax under sections 6653(a)(1) for negligence and 6661 for                
          substantial understatement of tax.                                          
               Petitioner has conceded the disallowance of the $813,462               
          claimed interest expense deduction and the addition to tax under            
          section 6653(a)(1).                                                         

          Discussion                                                                  
               Under section 6661(b)(1)(A), a substantial understatement of           
          tax occurs where the understatement exceeds the greater of $5,000           
          or 10 percent of the amount of tax required to be shown on the              
          return.  The amount of the addition to tax is equal to 25 percent           
          of any underpayment attributable to the substantial                         
          understatement.  Sec. 6661(a).                                              
               The understatement may be eliminated if substantial                    
          authority existed for the claimed tax treatment of the item to              
          which the addition to tax relates or if relevant facts regarding            
          the taxpayer’s treatment of the item were adequately disclosed by           
          the taxpayer on the tax return or in a statement attached to the            
          return.  Sec. 6661(b)(2)(B); sec. 1.6661-4(a), Income Tax Regs.             
               The adequate disclosure standard will be treated as                    
          satisfied where a taxpayer provides information on the tax return           
          "that reasonably may be expected to apprise the Internal Revenue            
          Service of the identity of the item, its amount, and the nature             





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