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taxpayer acted in good faith. See sec. 6664(c); sec. 1.6664-
4(a), Income Tax Regs. Respondent's determination imposing the
accuracy-related penalty is presumed correct, and petitioners
must establish error in respondent's determination that they are
liable for the penalty. Rule 142(a); Estate of Monroe v.
Commissioner, 104 T.C. 352, 366 (1995).
The record contains no evidence as to petitioners'
reasonable cause or good faith for claiming the deductions in
issue nor any other evidence that would show error in
respondent's determination of the penalty. Accordingly, we
sustain respondent's determination that petitioners are liable
for the accuracy-related penalty under 6662(a) for 1996.
To reflect the foregoing and respondent's concessions,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011