Larry Dean Sykes and Ruby Sykes - Page 23




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          comply with internal revenue laws or to exercise ordinary and               
          reasonable care in preparing a tax return.  See sec. 6662(c).               
          An understatement is substantial if it exceeds the greater of 10            
          percent of the tax required to be shown on the return or $5,000.            
          See sec. 6662(d)(1)(A).                                                     
               Petitioners concede that they are liable for the section               
          6662 accuracy-related penalty if we find that they earned any of            
          the $149,200 seized from petitioner’s participation in a fencing            
          operation in 1997.  Because we found that petitioners had                   
          unreported taxable income of $109,200 from petitioner’s                     
          participation in the fencing operation in 1997, we hold that                
          petitioners are liable for the section 6662 accuracy-related                
          penalty for 1997.                                                           
               To reflect the foregoing,                                              
                                                  Decision will be entered            
                                             under Rule 155.                          




















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