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Respondent determined that petitioners are liable for
accuracy-related penalties pursuant to section 6662(b)(1). The
penalty applies to any underpayment due to negligence or
intentional disregard of rules or regulations. Petitioners did
not maintain adequate books and records. Sec. 6001. In
addition, they failed to exercise due care in reporting their
income. Accordingly, petitioners are liable for the section 6662
accuracy-related penalties.
To reflect the foregoing,
Decision will be entered
pursuant to Rule 155.
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Last modified: May 25, 2011