- 21 - 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 sectionPage: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Next
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