- 23 -
would have been liable for section 6662(a)'s penalty for a
substantial understatement of tax to the extent that the Rule 155
computation indicated that petitioners' understatement of tax
exceeded the greater of 10 percent of the amount of tax required
to be shown on the return or $5,000.
We have considered all other arguments made by petitioners
and found them to be either irrelevant or without merit.
To reflect the foregoing and concessions,
Decision will be entered
under Rule 155.
Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Last modified: May 25, 2011