- 27 - because of respondent’s agent’s advice that the period for assessment of Career’s tax for its 1992 fiscal year had expired. The testimony of petitioners’ certified public accountant does not support petitioners’ claim that respondent’s agent is in any way responsible for petitioners’ being subject to the determined penalties. Other than those assertions, petitioners have not presented any evidence or made any other showing as to why respondent’s penalty determinations are in error. Although a Rule 155 computation will be necessary to determine the penalty amounts, if any, for each petitioner, we hold that petitioners have failed to show that respondent erred in determining any of the section 6662(a) penalties. To reflect the foregoing, Decisions will be entered under Rule 155.Page: Previous 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27
Last modified: May 25, 2011