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the greater of $5,000 or 10 percent of the amount required to be
shown on the return.10 On this record, the Court holds that
petitioner is liable for the addition to tax under section
6661(a) for a substantial understatement of tax for 1982.
Respondent is sustained on this issue.
Decision will be entered
for respondent.
10 The amount required to be shown on the return was
$34,551, 10 percent of which equals $3,455.10.
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