- 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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