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they produce substantial authority for their position. The
underpayment upon which the addition to tax was imposed was
$10,460. The understatement is substantial because it exceeds
the greater of $5,000 or 10 percent of the amount required to be
shown on the return. Accordingly, we sustain respondent's
determination as to the addition to tax under section 6661(a).
To the extent that we have not addressed any of the parties'
arguments, we have considered them and conclude they are without
merit.
Reviewed and adopted as the report of the Small Tax Case
Division.
Decision will be entered
for respondent.
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Last modified: May 25, 2011