Miguel Espinoza and Mariaclariza Montoya - Page 13




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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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