- 10 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10
Last modified: May 25, 2011