- 11 - Petitioners also argue that, for purposes of section 6662(a), any understatement of tax should be calculated with respect to their amended tax return, not their original tax return. Under section 1.6664-2T(c)(2), Temporary Income Tax Regs., 56 Fed. Reg. 67505 (Dec. 31, 1991), however, an amended tax return can be used to determine a taxpayer’s underpayment for purposes of section 6662(a) only if the amended return is filed before the taxpayer is first contacted by respondent with respect to the year involved. As we have found, respondent contacted petitioners no later than October 6, 2003, and petitioners did not file their amended 2001 joint Federal income tax return until February 3, 2004. We have considered all arguments made herein, and, to the extent not addressed, we conclude that they are without merit or are irrelevant. To reflect the foregoing, Decision will be entered under Rule 155.Page: Previous 1 2 3 4 5 6 7 8 9 10 11
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