- 6 -
record, we conclude that petitioners have not established that
their underpayment was due to reasonable cause or that they acted
in good faith. Accordingly, we hold that petitioners are liable
for a section 6662(a) accuracy-related penalty for the tax year
1994 as determined by respondent.
Decision will be entered
under Rule 155.
Page: Previous 1 2 3 4 5 6
Last modified: May 25, 2011