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petitioners were negligent in failing to report petitioner's
income from JMS. Except for the amount of the compensation that
petitioner received from JMS during 1992, petitioners do not
contest respondent's determination under section 6662(a).
On the record before us, we find that petitioners are liable
for 1992 under section 6662(a) for the accuracy-related penalty
on the underpayment of tax attributable to $9,100 of income from
JMS that petitioners did not report in their 1992 return.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011