- 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