- 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.Page: Previous 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38
Last modified: May 25, 2011