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reasonable cause for petitioners' reporting position or that they
acted in good faith. Respondent is sustained on this issue.6
To reflect the foregoing,
Decision will be entered
under Rule 155.
6Because we have found that petitioners are liable for the
accuracy-related penalty for negligence or disregard of rules or
regulations, we need not decide the issue of whether petitioners
are liable for the penalty for the substantial understatement of
income tax. See sec. 1.6662-2(c), Income Tax Regs.
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Last modified: May 25, 2011