- 40 -
in question did not constitute gross income, and did not
disclose the facts relating to these items in their returns
or statements attached to their returns. Accordingly, we
sustain respondent's determination that petitioners are
liable for the addition to tax for substantial under-
statement of liability as prescribed by section 6661 with
respect to their 1988 return, and the accuracy-related
penalty as prescribed by section 6662 with respect to their
1989 return, insofar as they have understated their income
tax liability. However, because respondent has conceded a
portion of the deficiency, and because we have found for
petitioners on others, the amounts of the addition to tax
and penalty shall be determined as part of the Rule 155
computation.
In light of the foregoing, and reflecting concessions,
Decision will be entered
under Rule 155.
Page: Previous 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 Last modified: May 25, 2011