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10 percent of the tax required to be shown on the return or
$5,000. Sec. 6661(b)(1)(A). The deficiency in tax we have
determined represents a substantial understatement.
Under the facts established in the record, petitioners are
liable for the addition to tax under section 6661 for 1986.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011