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petitioner did not file an amended 1993 income tax return until
1997, after the commencement of respondent’s audit. We hold that
respondent has proved that petitioners were negligent and did not
act with good faith and reasonable cause with respect to the
unreported net income from Ortega. Accordingly, petitioners are
liable for the accuracy-related penalty for negligence under
section 6662(a).
To reflect the foregoing,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011