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various entries on his return. Petitioner misunderstands, and
does not meet, the requirement of section 6662(d)(2)(B), which is
that disclosures be on the return or a statement attached
thereto. Petitioner made no such disclosure. See sec. 1.6661-
4(a), Income Tax Regs. Accordingly, there is no reduction in the
understatement.
The question of whether there is a substantial
understatement of income tax thus depends upon the amount of the
understatement, which will be addressed in the Rule 155
computation. The understatement shall not include any portion of
the underpayment for which we have herein found there was
reasonable cause under section 6664(c)(1).
We have considered all other arguments made by petitioner
and found them to be either irrelevant or without merit.
To reflect the foregoing and concessions,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011