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None of petitioners made any disclosures with their returns.
Petitioners' only argument is that there is no deficiency, so
there can be no addition under section 6661. Should any of their
respective understatements of tax as recalculated in accordance
with this opinion be substantial, we hold that the respective
petitioner is liable for the addition to tax under section 6661
for that year.
In keeping with the foregoing,
Decisions will be entered
under Rule 155.
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