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liability for 1996 of $5,441. However, their liability is
$24,861. Thus, respondent has satisfied the burden of production
under section 7491(c).
We deem petitioners to have conceded that they are liable
for the accuracy-related penalty under section 6662(a) for
substantial understatement of their 1996 income tax because they
make no argument about the penalty. See Levin v. Commissioner,
87 T.C. 698, 722-723 (1986) (we deemed the taxpayers to have
abandoned claims in the petition for which they made no
argument), affd. 832 F.2d 403 (7th Cir. 1987); Zimmerman v.
Commissioner, 67 T.C. 94, 104 n.7 (1976) (we deemed the taxpayers
to have conceded an issue they raised in their petition because
they made no argument at trial or on brief relating to that
issue). We conclude that petitioners are liable for the
accuracy-related penalty under section 6662(a) for substantial
understatement of income tax for 1996.
For the foregoing reasons,
Decision will be
entered for respondent.
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