- 52 -- 52 -
tent that it relates to the underpayment attributable to that in-
come would be correct. In light of that concession and our find-
ings that petitioners have unreported income for 1989 and 1990
resulting from those deposits in the total amount of $174,030.35
and $101,751.77, respectively, we sustain respondent’s determina-
tion imposing the accuracy-related penalty for each of those
years to the extent that it relates to the underpayment for each
such year attributable to such unreported income.36
To reflect the foregoing and the concessions of the parties,
Decision will be entered
under Rule 155.
36 Petitioners do not dispute, and we assume that they also
concede, the imposition of the accuracy-related penalty for 1989
relating to their unreported income for that year in the amount
of $2,500 from the sale of plans.
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