David Carkhuff and Tonja Carkhuff - Page 8
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includes any careless, reckless, or intentional disregard. Sec.
6662(c). The deemed admissions establish that petitioners are
liable for the penalty with regard to the entire underpayment.
The deemed admissions establish that no genuine issue of material
fact exists as to the issue of negligence and, therefore,
respondent is entitled to a decision on this issue as a matter of
Accordingly, respondent's Motion for Summary Judgment will
be granted as to all issues.
To reflect the foregoing,
An appropriate order and
decision will be entered granting
respondent's motion for summary
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Last modified: May 25, 2011