- 19 - 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.Page: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20Last modified: November 10, 2007