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percent addition to tax for failure to timely file his 1991 tax
return.
Issue 5. Accuracy-Related Penalty
The final issue for decision is whether petitioner is liable
for the accuracy-related penalty for the substantial understatement
of tax pursuant to section 6662. Petitioner asserts that he had
reasonable cause for the understatement of tax.
Section 6662 imposes an accuracy-related penalty equal to 20
percent of any portion of an understatement attributable to a
substantial understatement. A substantial understatement means an
understatement which exceeds the greater of 10 percent of the tax
required to be shown on the return or $5,000. Sec. 6662(d)(1).
The understatement is reduced by that portion of the understatement
for which the taxpayer had substantial authority or for which the
taxpayer adequately disclosed the relevant facts in the return.
Sec. 6662(d)(2)(B). Additionally, no penalty is imposed with
respect to any portion of an understatement as to which the
taxpayer acted with reasonable cause and in good faith. Sec.
6664(c)(1).
Petitioner provided no disclosures in his return and supplied
this Court with no substantial authority for his positions. See
sec. 1.6662-4(d)(3), Income Tax Regs. Also, he failed to prove
that his effort to assess his proper tax liability was sufficient
to establish reasonable cause and good faith. See sec. 1.6664-
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