Tina & Sheafen Kuo - Page 9




                                        - 8 -                                         
               Petitioners have failed to introduce any evidence that would           
          show reasonable cause and good faith on their part.  On the                 
          contrary, the record shows an absence of adequate books and                 
          records and meager efforts to properly assess their tax liability           
          for 1996.  We uphold respondent’s determination that petitioners            
          are liable for the accuracy-related penalty.                                
               Reviewed and adopted as the report of the Small Tax Case               
          Division.                                                                   
               To reflect the foregoing,                                              
                                             Decision will be entered                 
                                        under Rule 155.                               





























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