David E. and Rebecca Newman - Page 13

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                  As such, we find that petitioners failed to make any                                 
            reasonable attempt to comply with the tax laws and carelessly                              
            disregarded rules and regulations relating to the proper                                   
            reporting of items and record keeping.  Accordingly, we sustain                            
            respondent’s determination and hold that petitioners are liable                            
            for the section 6662(a) accuracy-related penalty for the 1991 and                          
            1992 tax years.                                                                            
                  We have considered all other arguments of the parties, and                           
            to the extent not addressed herein, we find them to be either                              
            meritless or irrelevant.                                                                   
                  To reflect the foregoing and concessions of the parties,                             
                                                      Decision will be entered                         
                                                under Rule 155.                                        

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