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10 percent of the tax required to be shown on the return for the
taxable year in issue and $5,000. See sec. 6661(b)(1)(A).
Accordingly, petitioner’s understatement is substantial. Neither
exception under section 6661(b)(2)(B) applies because no amounts
were adequately disclosed or supported by substantial authority.
We have considered all arguments made by the parties, and to
the extent not mentioned above, we find them to be irrelevant or
without merit.
To reflect the foregoing,
An appropriate order and
decision will be entered.3
3 It is undisputed that petitioner has paid to respondent
$2,925 in restitution pursuant to the order of the U.S. District
Court. We expect petitioner to be given credit for his $2,925
restitution payment for taxable year 1986. Cf. M.J. Wood
Associates, Inc. v. Commissioner, T.C. Memo. 1998-375.
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