Nelson J. and Victoria A. Secretario - Page 6

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          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.                          

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