- 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.
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Last modified: May 25, 2011