- 11 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11
Last modified: May 25, 2011