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We turn now to the issue presented under section 6662.
Respondent determined that petitioners in each of these cases are
liable for 1999 for the accuracy-related penalty under section
6662(a) because of a gross valuation misstatement under section
6662(h). In the alternative, respondent determined that peti-
tioners are liable for 1999 for that penalty because of negli-
gence or disregard of rules or regulations under section
6662(b)(1) or a substantial understatement of tax under section
6662(b)(2). On brief, respondent concedes that if the Court were
to find that petitioners are not entitled for 1999 to the respec-
tive charitable contribution deductions that they are claiming
“on the ground that KQC did not transfer property to TMC in 1999,
or on the ground that KQC did not meet the substantiation re-
quirements of I.R.C. � 170”, petitioners would not be liable for
the accuracy-related penalty because of a gross valuation mis-
statement under section 6662(h). Consequently, we consider only
respondent’s alternative argument that petitioners are liable for
the accuracy-related penalty under section 6662(a) because of
negligence or disregard of rules or regulations under section
6662(b)(1) or a substantial understatement of tax under section
6662(b)(2).
Section 6662(a) imposes an accuracy-related penalty equal to
20 percent of the underpayment of tax attributable to, inter
alia, a substantial understatement of tax, sec. 6662(b)(2). An
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