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reasons for failing to file timely, which we have found to be
unconvincing. Petitioners do not contend that they had
substantial authority for the understatements or that their tax
returns disclosed enough facts to enable respondent to identify
the potential controversy. See sec. 6662(d)(2)(B); Schirmer v.
Commissioner, 89 T.C. 277, 285-286 (1987). We conclude that
petitioners are liable for the additions to tax under section
6661(a) for 1985 and 1987 and the accuracy-related penalties
under section 6662(b)(2) and (d) for 1989 and 1990 if the
calculations under Rule 155 show that the understatements are
substantial for purposes of section 6661(a) or section
6662(d)(1).
To reflect concessions and the foregoing,
Decision will be entered
under Rule 155.
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