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attorney or accountant. Cf. United States v. Boyle, 469 U.S.
241, 251 (1985).
Section 6662(d)(1)(A) provides another ground for sustaining
the penalty. It penalizes a substantial understatement, defined
as one that is the greater of ten percent of the tax required to
be shown on the return or $5,000. The understatements on the
brothers’ returns meet this definition for both years. To
reflect concessions and settlements on other issues, though,
Decisions will be entered
under Rule 155.
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Last modified: May 25, 2011