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items of income, loss, deduction, or credit. See sec. 1366(a).
Petitioners presented no credible evidence relating to this
issue. Accordingly, we sustain respondent’s adjustment of
petitioners’ 1994 income.
IV. Accuracy-Related Penalty
Respondent determined that petitioners were negligent in
determining their 1994 tax liability and are liable for a section
6662 penalty. The penalty applies to the portion of petitioners’
underpayment that is attributable to negligence or disregard of
rules or regulations. Sec. 6662(b)(1). Petitioners did not make
a reasonable attempt to report accurately some of their
deductions. As a result, petitioners are liable for the
accuracy-related penalty.
Contentions we have not addressed are moot, irrelevant, or
meritless.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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