- 23 - 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.Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23
Last modified: May 25, 2011