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C. Conclusion
Based either on the negligence of petitioners or their
substantial understatements of income tax, the motions for
partial summary judgment shall be granted. Petitioners are
liable for the section 6662 penalties determined by respondent.
III. Orders To Show Cause
A. Penalty Pursuant to Section 6673(a)(1)
1. Introduction
Petitioners in each of these cases have been ordered to show
cause why the Court should not impose a penalty pursuant to
section 6673(a)(1) (the order to show cause or the order). No
petitioner has obeyed the order. Respondent has filed his
memorandum of points and authorities in support of the order
(respondent’s memorandum). For the reasons that follow, we shall
make the order to show cause absolute.
2. Section 6673(a)(1)
Section 6673 provides for the imposition of penalties and
the awarding of costs. Section 6673(a) applies to proceedings
before the Tax Court; in pertinent part, it provides:
(1) Procedures instituted primarily for delay,
etc.
Whenever it appears to the Tax Court that--
(A) proceedings before it have been
instituted or maintained by the taxpayer
primarily for delay,
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