The Escrow Connection, Inc., A.K.A. The Escrow Connection - Page 28

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               Respondent determined an addition to tax of $40,349 under              
          section 6661 for taxable year ended July 31, 1989.  Section                 
          6661(a) imposes an addition to tax of 25 percent of the amount              
          of any underpayment attributable to a substantial understatement            
          of tax.  An understatement is the difference between the amount             
          required to be shown on the return and the amount actually shown            
          on the return and is substantial if it exceeds the greater of               
          (1) 10 percent of the tax required to be shown on the return for            
          a taxable year, or (2) $10,000.  Sec. 6661(b)(1) and (2)(A);                
          Tweeddale v. Commissioner, 92 T.C. 501, 505 (1989).  The amount             
          of the understatement can be reduced if substantial authority               
          existed for the taxpayer's tax treatment of the item in dispute             
          or if the taxpayer adequately disclosed relevant facts regarding            
          the taxpayer's treatment of the item in the return or in a                  
          statement attached to the return.  Sec. 6661(b)(2)(B).  The                 
          taxpayer has the burden of proving it is not liable for the                 
          addition to tax.  Rule 142(a).  Petitioner does not contend that            
          substantial authority existed for its position or that it                   
          adequately disclosed the relevant facts.                                    
               Rather, petitioner maintains that it had reasonable cause              
          for the understatement.  Section 6661(c) provides that the                  
          Commissioner may waive the addition to tax if the taxpayer                  
          proves that reasonable cause existed for the understatement and             
          the taxpayer acted in good faith.  The most important factor in             





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