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petitioners have not established that the underpayment of tax was
due to reasonable cause and that they acted in good faith.
Accordingly, we hold petitioners are liable for the accuracy-
related penalty. On account of respondent's concession, the
penalty will be in an amount less than that determined in the
notice of deficiency.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011