Judith M. De Shon and Michael J. De Shon - Page 12

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          account.  Moreover, the mailing address on the August 2000                  
          monthly statement was the same as petitioners’ current mailing              
          address.                                                                    
               On the one hand, Mr. De Shon testified at trial that he had            
          no knowledge of this account, but, on the other hand, he                    
          testified that he had no knowledge of a lot of paperwork in Mrs.            
          De Shon’s possession.  Mr. De Shon’s conflicting testimony leads            
          to an inference that petitioners, either jointly or separately,             
          in fact maintained account 879.                                             
               On the basis of the record, we conclude that petitioners               
          received discharge of indebtedness income from account 879 of               
          $3,617 in 2001.  Accordingly, we sustain respondent’s                       
          determination on this issue.                                                
          B.   Section 6662(a) Penalty                                                
               In the notice of deficiency, respondent determined that                
          petitioners are liable under section 6662(a) for an underpayment            
          of tax that is attributable to substantial understatement of                
          income tax.                                                                 
               Section 6662(a) imposes a penalty equal to 20 percent of any           
          underpayment of tax that is attributable to substantial                     
          understatement of income tax.  See sec. 6662(a) and (b)(2).  An             
          understatement of income tax is “substantial” if it exceeds the             
          greater of 10 percent of the tax required to be shown on the                
          return, or $5,000.  Sec. 6662(d)(1)(A).  An “understatement” is             






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