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portion of the underpayment that is attributable to negligence or
disregard for rules or regulations. Sec. 6662(b). Petitioners
failed to exercise due care in reporting their income and
expenses. In addition, petitioners submitted altered documents
to the IRS and to the Court. Accordingly, they are liable for
the accuracy-related penalty.
To reflect the foregoing and concessions by respondent,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011