- 8 - 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 law. 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 judgment.Page: Previous 1 2 3 4 5 6 7 8
Last modified: May 25, 2011