Sudhir P. Srivastava and Elizabeth S. Pascual - Page 40

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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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