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for summary judgment. We treat this as a concession by
petitioners. Rothstein v. Commissioner, 90 T.C. 488, 497 (1988);
Reaves v. Commissioner, 31 T.C. 690, 722 (1958), affd. 295 F.2d
336 (5th Cir. 1961). Also, respondent asked petitioners to admit
that they were negligent with respect to the entire underpayment.
In their motion to withdraw deemed admissions, which was filed
more than 2 months after respondent filed and served the request
for admissions, petitioners denied they were negligent. However,
we deem admitted that petitioners were negligent with respect to
the entire underpayment.
We conclude that petitioners are liable for the accuracy-
related penalty for 1992 under section 6662(a) for negligence and
that all of the deficiency is due to negligence.
To reflect respondent's concession and the foregoing,
An appropriate order
and decision will be
entered for respondent.
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