Mary T. King and Fatai O. King - Page 21




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             substantiated these alleged cash expenditures in the                       
             aggregate amount of $520.                                                  
                  The next issue for decision is whether petitioners are                
             liable for the accuracy-related penalty under section                      
             6662(a) for 1993.  At the outset, we note that in the                      
             notice of deficiency, the amount of the addition to tax for                
             delinquency under section 6651(a)(1), $2,736, is switched                  
             with the amount of the penalty for substantial                             
             understatement under section 6662(a), $5,463, and vice                     
             versa.  This appears to be a typographical error.  The                     
             notice makes reference to an enclosed statement that “shows                
             how [respondent] figured the deficiency.”  The enclosed                    
             statement shows respondent’s computation of the additions                  
             to tax for delinquency and the penalty for substantial                     
             understatement and relates these amounts to the appropriate                
             statutory provisions.  Petitioners did not make an issue of                
             this error in their petition or at trial, and there is no                  
             evidence that they were uncertain about the amounts that                   
             were determined by respondent.  Thus, we need not address                  
             this matter.  See Goodman v. Commissioner, T.C. Memo. 1985-                
             151 (relying on Mayerson v. Commissioner, 47 T.C. 340                      
             (1966)).                                                                   
                  Respondent determined that petitioners are liable for                 
             an accuracy-related penalty of $5,463 under section                        






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