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Petitioners fail to address this issue in meaningful detail.
They limit their argument to the contention that there is no
underlying deficiency. Accordingly, under the facts and
circumstances of this case, we conclude that petitioners have not
carried their burden of refuting respondent's determination with
respect to this issue. Respondent's determination is sustained.6
To reflect the foregoing,
Decision will be
entered under Rule 155.
6Respondent also argues that petitioners were negligent, but
because we hold petitioners liable for the accuracy-related
penalty due to their substantial understatement of income tax, we
do not address the negligence issue.
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