- 21 - to the additions to tax under section 6653(a) for 1986, 1987, and 1988 and the penalties under section 6662(a) for 1989 and 1990. Section 6661(a) provides that "If there is a substantial understatement of income tax for any taxable year, there shall be added to the tax an amount equal to 25 percent of the amount of any underpayment attributable to such understatement." See also Pallottini v. Commissioner, 90 T.C. 498 (1988). There is a substantial understatement if the amount of the understatement exceeds the greater of $5,000 or 10 percent of the tax required to be shown on the return. Sec. 6661(b)(1)(A). The amount of the understatement shall be reduced if there is substantial authority for the tax treatment of any item or there is disclosure of the relevant facts affecting the item's tax treatment. Sec. 6661(b)(2)(B). The understatements of tax here essentially result from unreported income and the disallowed NOL carryovers, and are substantial under section 6661(b)(1). There was no substantial authority for either position taken, nor was there adequate disclosure of the relevant facts. Therefore, we sustain respondent's determinations with respect to the additions to tax under section 6661(a) for 1986, 1987, and 1988. Tax on Self-Employment Income Section 1401(a) imposes a tax "on the self-employment income of every individual". As we understand it, petitioner does not dispute that he is liable for the tax. Rather, he contends that his self-employment income should not be increased by thePage: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
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