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incorrect opinion.
We therefore find that petitioners are liable for the
section 6662(a) penalty for the portion of any underpayment of
the tax required to be shown on the return that is due to not
reporting the interest portion of the settlement amount as
income.
Due to our finding that petitioners are liable for the
accuracy-related penalty for the substantial understatement of
tax, we need not address the issue of whether they are liable for
the accuracy-related penalty for negligence or disregard of rules
or regulations. See sec. 1.6662-2(c), Income Tax Regs.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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