Richard and Arline Muller - Page 8




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          information relating to the IRA distribution.  Petitioners have             
          failed to establish that the good faith exception applies to the            
          imposition of the section 6662(a) accuracy-related penalty.  See            
          Higbee v. Commissioner, 116 T.C. 438 (2001).  Respondent’s                  
          imposition of that penalty is sustained.                                    
               To reflect the foregoing,                                              

                                             Decision will be entered                 
                                        for respondent.                               
































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