- 10 - the interest was not taxable to them because they did not own the Liu accounts. Respondent also determined that petitioners were liable for the following penalties under section 6662(a): (1) Substantial understatement (1990) and (2) negligence (1991). Section 6662(a) imposes an accuracy-related penalty equal to 20 percent of the portion of an underpayment that is attributable either to negligence or to a substantial understatement of tax. See also sec. 6662(b)(1) and (2). Petitioners contend that neither of these penalties applies to this case because they did not have a deficiency in either year. We have sustained respondent's determinations of the deficiencies. The record does not otherwise disprove respondent's determination as to these penalties. We also sustain her determination of them. With respect to each issue in this case, we have considered all arguments made by petitioners, and, to the extent not addressed above, find them to be irrelevant or without merit. To reflect the foregoing, Decisions will be entered under Rule 155.Page: Previous 1 2 3 4 5 6 7 8 9 10
Last modified: May 25, 2011