- 15 - other than their claim that there is no section 7872 adjustment producing an understatement. (Petitioners do not contend that they have substantial authority or that they adequately disclosed the understatement under sec. 6661(b)(2)(B)(i) and (ii).) Since we have held otherwise, if the recomputed deficiency under Rule 155 satisfies the statutory percentage or amount, petitioners will be liable for such additions to tax. See Cluck v. Commissioner, 105 T.C. 324 (1995). We have considered petitioners' other arguments, and to the extent that they are not addressed herein, we find them to be either irrelevant or without merit. To reflect the foregoing, Decision will be entered under Rule 155.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15
Last modified: May 25, 2011