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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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