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find that petitioners have failed to establish any error in
respondent’s determination that they are liable for the year at
issue for the accuracy-related penalty under section 6662(a)
insofar as it relates to the underpayment of tax attributable to
petitioners’ capital gain. Consequently, we sustain that deter-
mination to that extent.
We have considered all of the contentions and arguments of
petitioners that are not discussed herein, and we find them to be
without merit and/or irrelevant.
To reflect the foregoing and the concessions of the parties,
Decision will be entered under
Rule 155.
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