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.Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22
Last modified: May 25, 2011