- 15 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15
Last modified: May 25, 2011