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incurred deductible truck expenses of $1,500 for 1990.
We have considered the parties' remaining arguments
concerning the amounts of the deficiencies for the years in issue
and find those arguments to be either without merit or
unnecessary to reach.
III. Substantial Understatement
Section 6661(a) imposes an addition to tax of 25 percent of
any underpayment attributable to a substantial understatement of
tax. A substantial understatement is any understatement which
exceeds the greater of (1) 10 percent of the tax required to be
shown on the return or (2) $5,000. Sec. 6661(b)(1)(A). If the
taxpayer has substantial authority for the tax treatment of the
item in question, or if the taxpayer adequately discloses the tax
treatment of the item on the return, then the amount of the
understatement for purposes of this section will be reduced by
that portion of the understatement which is attributable to that
item. Sec. 6661(b)(2)(B).
Petitioner made no disclosures with his returns for the
years in issue. Petitioner argues simply that there is no
underpayment of tax for any of the years in issue which
constitutes a substantial understatement of income tax within the
meaning of section 6661. Consequently, should either the 1987 or
the 1988 understatement of tax as recalculated in accordance with
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