Ivan Andre Zaal - Page 6

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          that is actually shown on the return.  Sec. 6662(d)(2)(A).  An              
          understatement is "substantial" if the amount exceeds the greater           
          of 10 percent of the tax required to be shown on the return or              
          $5,000.  Sec. 6662(d)(1)(A).  Petitioner's omission from his tax            
          return of insurance renewal commissions in the amount of $113,081           
          results in a substantial understatement.                                    
               Petitioner may avoid liability for the accuracy-related                
          penalty in either of two ways.  First, if there is or was                   
          substantial authority for petitioner's tax treatment of any                 
          portion of the understatement, that portion would be excluded               
          from the penalty computation.  Sec. 6662(d)(2)(B)(i).                       
               To determine whether the treatment is supported by                     
          substantial authority, the weight of the authorities in support             
          of petitioner's position must be substantial in relation to the             
          weight of the authorities supporting contrary positions.                    
          Antonides v. Commissioner, 91 T.C. 686, 700-704 (1988), affd. 893           
          F.2d 656 (4th Cir. 1990); sec. 1.6662-4(d)(3), Income Tax Regs.             
          There are no authorities that support petitioner's treatment.               
          Indeed, the weight of the authorities, discussed supra, clearly             
          rejects petitioner's treatment of the renewal commissions.  Thus,           
          petitioner does not qualify under this exception.                           
               Second, petitioner's liability could be reduced if                     
          petitioner had adequately disclosed the relevant facts on his tax           
          return and there was a reasonable basis for the treatment of the            





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