- 7 - 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.Page: Previous 1 2 3 4 5 6 7
Last modified: May 25, 2011