- 40 - 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.Page: Previous 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40
Last modified: May 25, 2011