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return for the taxable year over the amount shown on the return.
An understatement is substantial if it exceeds the greater of
10 percent of the tax required to be shown on the return or
$5,000. Sec. 6661(b)(1)(A).
Petitioners did not present evidence that would bring them
within any exception to applicability of section 6661.
Accordingly, we conclude that petitioners are liable for the
addition to tax under that section for 1988.
To reflect the foregoing and concessions of the parties,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011