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v. Commissioner, 85 T.C. 267, 272 (1985); Morrison v.
Commissioner, 81 T.C. 644, 651 (1983).
We conclude that there are no genuine issues of material
fact and that respondent is entitled to a decision as a matter of
law on the issue of petitioners' unreported income. Rule 121(b).
We sustain the determination, reduced as conceded by respondent,
and hold that petitioners received but did not report $28,887.90
as income for petitioner's services as a religious official in
1992.
C. Whether Petitioners Are Liable for the Accuracy-Related
Penalty Under Section 6662(a)
Respondent determined that petitioners are liable for the
accuracy-related penalty for negligence for 1992 under section
6662(a).
Taxpayers are liable for a penalty equal to 20 percent of
the part of the underpayment to which section 6662 applies. Sec.
6662(a). For purposes of section 6662(a), negligence includes
any failure to make a reasonable attempt to comply with the
provisions of the Internal Revenue Code. Sec. 6662(c). The
accuracy-related penalty under section 6662(a) does not apply to
any part of an underpayment if the taxpayer shows that there was
reasonable cause for that part and that the taxpayer acted in
good faith. Sec. 6664(c)(1).
Petitioners did not argue that they are not liable for the
accuracy-related penalty in their response to respondent's motion
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