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and in good faith in claiming deductions for the expenses listed
in their 1994 Schedule C. Consequently, we sustain respondent's
determination imposing the accuracy-related penalty under section
6662(a) for 1994 to the extent that those claimed deductions
resulted in an underpayment of tax required to be shown in
petitioners' return for that year.
To reflect the foregoing and the concessions of petitioners,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011