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supports the conclusion that petitioners did not make a
reasonable attempt to comply with internal revenue laws and did
not act with reasonable cause and in good faith.
We therefore sustain respondent's determination and hold
that petitioners are liable for the accuracy-related penalty
under section 6662(a) for the year in issue with respect to the
underpayment attributable to their unreported net earnings from
self-employment.
Conclusion
To reflect our disposition of the disputed issues, as well
as the parties' concessions,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011