Raymond K. and Minerva R. Mason - Page 15

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          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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