Larry Whittington - Page 11




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          6661(b).  Petitioners' understatements were not based on                    
          substantial authority or adequately disclosed.  Accordingly, if             
          the recomputed deficiencies satisfy the statutory percentage or             
          amount, petitioners will be liable for those additions to tax.              
          See, e.g., Cluck v. Commissioner, 105 T.C. 324, 340 (1995).                 
               All other contentions raised by the parties are either moot,           
          meritless, or irrelevant.                                                   
               To reflect the foregoing,                                              

                                                  Decisions will be entered           
                                             under Rule 155.                          






























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Last modified: May 25, 2011