Kai H. and Susanna Lee - Page 11

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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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