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Furthermore, in this case, each petitioner has placed the
responsibility for the omissions from income and the claimed
excess deductions on the shoulders of the other. Petitioner
husband testified that petitioner, not he, was responsible for
reporting the income and expenses with regard to her property.
For her part, petitioner did not examine the returns for
accuracy. She testified that petitioner husband was responsible
for the returns, and "he would bring them home and say 'sign on
the X' and I'd sign on the X and that would be the end of that."
Therefore, neither petitioner made much effort to assess the
proper tax liability.
Accordingly, on the basis of all the facts and circumstances
of this case, we find that petitioners are liable for the section
6662(a) penalty for negligence or disregard of rules or
regulations.
To reflect the concessions of the parties and the foregoing,
Decision will be entered
under Rule 155.
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