David and Ira Kaye Kessel - Page 12




                                       - 11 -                                         

          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.                          























Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  

Last modified: May 25, 2011