- 28 - 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.Page: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Last modified: May 25, 2011