- 39 - 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.Page: Previous 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39
Last modified: May 25, 2011