Rogelio R. Balot and Zenaida V. Balot - Page 42

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          petitioners’ argument in support of their contention that                   
          reasonable cause excuses their 1993 underpayment:  “In fact, the            
          Taxpayers should not be subject to any civil tax penalties on the           
          tip income received from the Casino as they have reasonable cause           
          for their actions.”  Petitioners have not favored us with any               
          statement as to what is the “reasonable cause for their actions.”           
          In the absence of any explanation and any evidence that, on our             
          inspection, might constitute reasonable cause, we conclude that             
          section 6662(a) applies.                                                    
               To take account of respondent’s concessions and the                    
          foregoing,                                                                  
                                                        Decision will be              
                                                  entered under Rule 155.             

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