- 24 -
Petitioners contend that they should not be held liable for
the accuracy-related penalty because they readily conceded their
errors. We disagree. Conceding errors does not excuse the
underlying negligence.
Petitioners also contend that they should not be held liable
for the accuracy-related penalty because petitioner believed that
he needed to pay expenses from whatever accounts had funds. We
disagree. Petitioner could have recorded those payments
properly.
We conclude that petitioners are liable for the
accuracy-related penalty for negligence for 1990 and 1991 under
section 6662(a) and (c).
To reflect concessions and the foregoing,
Decision will be
entered under Rule 155.
Page: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Last modified: May 25, 2011