- 18 - we found were paid during that year with respect to the horse- training activities. We further hold that the underpayment for 1995 for purposes of section 6662(a) must be reduced to reflect that holding. On the record before us, we find that, except to the extent stated above, petitioner has failed to establish that he is not liable for the accuracy-related penalty under section 6662(a) for each of the years 1994 and 1995. Accordingly, except to that extent, we sustain respondent’s determinations that petitioner is liable for the accuracy-related penalty for each of those years.14 We have considered all of the contentions and arguments of petitioner that are not discussed herein, and we find them to be without merit and/or irrelevant. To reflect the foregoing and the concessions of respondent, Decision will be entered under Rule 155. 14Because certain of our holdings increase self-employment income for each of the years at issue, correlative adjustments must be made to self-employment tax for each such year. See supra note 5.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18
Last modified: May 25, 2011