Jin Xiong - Page 20




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          of a reasonable attempt to comply with the rules and/or                     
          regulations.  Therefore, under section 6662(b)(1), that part of             
          the underpayment attributable to these disallowed deductions is             
          subject to the section 6662(a) penalty even if the parties’ Rule            
          155 computation establishes that there was not a substantial                
          understatement of income tax.                                               
               Petitioner claimed a deduction for charitable contributions            
          of property in excess of the $500 we found to be the value of the           
          contributed property.  Again, independently of the outcome of the           
          parties’ Rule 155 computation, that part of the underpayment                
          attributable to this substantial valuation misstatement is                  
          subject to the section 6662(a) penalty under section 6662(b)(3).            
               To reflect the foregoing and concessions by the parties,               


                                                Decision will be entered              
                                           under Rule 155.                            




















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