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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.
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Last modified: May 25, 2011