Allie Ray McCullen and Shurley G. McCullen - Page 24

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               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.             



















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