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deficiencies exceed both 10 percent of the tax required to be
shown on the return and $5,000.
Petitioners presented no credible evidence that there
existed substantial authority for the erroneous treatment of any
item on their income tax returns or that any item was adequately
disclosed on their tax returns. Petitioners are liable for the
substantial understatement additions to tax pursuant to section
6661. See Slater v. Commissioner, T.C. Memo. 1996-366; Miravalle
v. Commissioner, T.C. Memo. 1994-49.
Decision will be entered
under Rule 155.
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