- 11 -
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