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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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Last modified: May 25, 2011