Dan E. and Susan J. Martens - Page 5




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          III. Accuracy-Related Penalties                                             
               Section 6662 imposes an accuracy-related penalty equal to 20           
          percent of any underpayment attributable to a substantial                   
          understatement of income tax.  See sec. 6662(a) and (b)(2).                 
          Petitioners have not established, pursuant to section 6664(c)(1),           
          that there was a reasonable cause and that they acted in good               
          faith in claiming the deductions.  Accordingly, petitioners are             
          liable for the accuracy-related penalties.                                  
               To reflect the foregoing,                                              


                                                  Decision will be entered            
                                             under Rule 155.                          



























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