- 13 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13
Last modified: May 25, 2011