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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.
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Last modified: May 25, 2011