- 12 - Petitioners contend that they are not liable for each of the years at issue for the accuracy-related penalty under section 6662(a) on the underpayment of tax for each such year that is attributable to the deductions with respect to the Paradise Lane property that they claimed in their returns for those years. On the record before us, we find that petitioners have failed to establish that they had reasonable cause and that they acted in good faith in claiming those deductions. See sec. 6664(c)(1); sec. 1.6664-4(a) and (b), Income Tax Regs. We further find on that record that petitioners have failed to show that they are not liable for each of the years at issue for the accuracy- related penalty under section 6662(a) on the underpayment of tax for each such year that is attributable to the deductions with respect to the Paradise Lane property that they claimed in their 1994 and 1995 returns. To reflect the foregoing and the concessions of the parties, An Order denying petitioners' motion to strike testimony will be issued, and decision will be entered under Rule 155.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12
Last modified: May 25, 2011