Robert E. Corrigan - Page 44

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          extent that a substantial understatement exists, the addition to            
          tax or penalty applies with respect to these items for 1987 and             
          1988.                                                                       
               As to whether petitioner adequately disclosed or had a                 
          reasonable basis for claiming Mrs. Corrigan’s personal exemption,           
          it is clear that he did not and that the substantial                        
          understatement penalty may apply for this item for 1987 and 1988.           
               To reflect the foregoing,                                              

                                                  Decision will be entered            
                                             under Rule 155.                          

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