22
96 (1990); Cramer v. Commissioner, 101 T.C. 225, 255 (1993),
affd. 64 F.3d 1406 (9th Cir. 1995); sec. 1.6661-3(b), Income Tax
Regs. In light of our discussion above, we conclude that the
authorities relied on by petitioners did not constitute
substantial authority.
Accordingly, if recomputation of petitioners' tax
liabilities reflects a substantial understatement, petitioner
Sands is liable for the addition to tax, and petitioners Heller
and Murphy are liable for the penalty.
To reflect the foregoing,
Decisions will be entered
under Rule 155.
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