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income tax return, and they failed to make a disclosure within
the meaning of section 6661(b)(2)(B)(ii).
For all of these reasons, therefore, we hold that
petitioners have failed to carry their burden of proof with
respect to the addition to tax under section 6661. If the
recomputed deficiency under Rule 155 attributable to respondent’s
determinations and the parties’ concessions in this case
satisfies the definition of substantial understatement under
section 6661(b)(1), petitioners will be liable for the addition
to tax under section 6661.
We have considered carefully all remaining arguments made by
petitioners for a result contrary to that expressed herein,
including arguments involving documents not in the record, and,
to the extent not discussed above, we find them to be irrelevant
or without merit.
To reflect the foregoing and the concessions of the parties,
Decision will be entered
under Rule 155.
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