- 9 - We do not consider that settlement here. See Fed. R. Evid. 408. Petitioners also contend that they have paid more tax than their coworkers, that respondent unreasonably refused to settle this case, and that respondent has harassed them. Petitioners state no details to support these claims, and we do not consider them further. 4. Conclusion We conclude that petitioners must include in income the $69,500 that petitioner withdrew from his IRA in 1996. B. Whether Petitioners Are Liable for the Accuracy-Related Penalty Respondent concedes that respondent bears the burden of production relating to petitioners’ liability under section 6662(a). Sec. 7491(c). The Commissioner satisfies the burden of production with respect to the accuracy-related penalty under section 6662 by coming forward with sufficient evidence indicating that it is appropriate to impose the relevant penalty; the Commissioner need not introduce evidence regarding reasonable cause, substantial authority, or similar provisions. Higbee v. Commissioner, 116 T.C. 438, 446 (2001); see H. Conf. Rept. 105- 599, at 241 (1998), 1998-3 C.B. 747, 995. A substantial understatement of tax exists if the amount of the understatement is more than 10 percent of the correct amount of tax or $5,000. Sec. 6662(d)(1)(A). Petitioners reported taxPage: Previous 1 2 3 4 5 6 7 8 9 10 Next
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