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for substantial understatement of income tax with respect to the
understatement attributable to his disallowed Villa del Mar legal
expenses for each year.14
Decision will be entered
under Rule 155.
14Although we have also determined that petitioner did not
have reasonable cause with respect to the underpayment
attributable to his disallowed 1994 Roadmaster Leasing
partnership loss, it does not appear (unless the Rule 155
computation shows otherwise) that he meets the sec. 6662(d)(1)
threshold for imposition of a penalty for that year.
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