Annette D. Goode-Parker - Page 10

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          “deficiency.”  But section 6211(a) does, as the “amount by which            
          the tax imposed * * * exceeds * * * the amount shown as the tax             
          by the taxpayer upon his return.”  Section 6015(b)--the section             
          requiring there to be an “understatement”--incorporates section             
          6662(d)(2)(A)’s definition of “understatement” as “the excess of-           
          -(i) the amount of tax required to be shown on the return for the           
          taxable year, over (ii) the amount of the tax imposed which is              
          shown on the return.”  Sec. 6662(d)(2)(A).                                  
               Whether there is an “understatement” or “deficiency” thus              
          turns on what tax is “shown” on a return with an error like the             
          one on the Parkers’ 1996 Form 1040.  Is the “tax shown” the                 
          amount that the Parkers entered on line 51 as their “total tax,”            
          or is it the amount entered in the IRS’s records after the                  
          “purple pencil people” noticed that the Parkers’ income tax and             
          self-employment tax, though both shown on the return, had not               
          been added?  The Commissioner argues that the tax “shown on the             
          return” was all the tax shown on any line of the return even if             
          not totaled up at the end.  If he’s right, there is no deficiency           
          (and no understatement either) because the tax imposed and the              
          tax shown on the return are equal, which makes the difference               
          between the two zero.  Ms. Goode-Parker disagrees.  She contends            
          that her husband’s mistake created both an understatement and a             
          deficiency because his mistake was a “mathematical error.”                  

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