Eloise Gaddy Joens - Page 28

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                  A taxpayer is liable for an addition to tax for substantial                         
            understatement equal to 25 percent of the understatement.5                                
            Pallottini v. Commissioner, 90 T.C. 498 (1988). An understatement                         
            is the excess of the corrected tax over the amount of tax                                 
            reflected on the return as filed.  Sec. 6661(b)(2).  An                                   
            understatement is "substantial" if it exceeds the greater of                              
            $5,000 or 10 percent of the corrected tax.  Sec. 6661(b)(1).                              
                  There was an understatement each year for the years in                              
            issue.  The understatements were "substantial" because they                               
            exceeded the greater of $5,000 or 10 percent of the corrected                             
            tax.  Accordingly, the additions to tax under section 6661 are                            
            sustained.                                                                                
                  For the foregoing reasons,                                                          


                                                            Decision will be entered                  
                                                      under Rule 155.                                 












                  5                                                                                   
                        This addition to tax does not apply to returns due                            
            after Dec. 31, 1989.                                                                      




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