- 37 -
In view of the foregoing, we hold that petitioner is liable
for the addition to tax under section 6661(a) for substantial
understatement of tax liability. Respondent’s determination is
sustained.
III. Conclusion
Reviewed and adopted as the report of the Small Tax Case
Division.
To reflect our disposition of the disputed issues, as well
as the parties’ concessions, see supra note 2,
Decision will be entered for
petitioner in docket No. 6294-00S.
Decision will be entered for
respondent in docket No. 6302-00S
as to the additions to tax under
sections 6653(a)(1) and 6661 as
determined in the notice of deficiency
and as to the addition to tax under
section 6653(a)(2) as claimed in
respondent's answer.
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