- 20 - the accuracy-related penalty. On this record, there is similarly no evidence that reasonable cause existed or that they were not negligent when they filed their respective 1992 gift tax returns. Accordingly, we sustain respondent's determinations against the transferees, the Larry Trust, the John Trust, and the Duane Trust, as to Kathy, Sandra, and Diane's liability for the accuracy-related penalty. In reaching our holdings herein, we have carefully considered all arguments made by the parties for a contrary result and, to the extent not discussed herein, find those arguments irrelevant or without merit. To reflect the foregoing, Decisions will be entered for respondent with respect to the deficiencies and for petitioners with respect to the penalties in docket Nos. 22141-97 and 22143-97; decisions will be entered for respondent in docket Nos. 22142-97, 22144-97, 469-98, 470-98, 471-98; and decisions will be entered for petitioners in docket Nos. 22145-97 and 22146-97.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20
Last modified: May 25, 2011