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statement of tax for each year at issue as a result of our
holdings in this case that exceeds the greater of 10 percent of
the tax required to be shown in petitioners’ joint return for
each such year or $5,000, see sec. 6662(d)(1)(A), petitioners
have failed to show that there is no substantial understatement
of tax under section 6662(b)(2) and (d). On that record, we
further find that petitioners have failed to show that they were
not negligent and did not disregard rules or regulations within
the meaning of section 6662(b)(1), or otherwise did what a
reasonable person would do, with respect to any portion of the
underpayment for each year at issue. On the record before us, we
also find that petitioners have failed to show that they acted
with reasonable cause and in good faith with respect to any
portion of the underpayment for each such year. See sec.
6664(c).
Based on our examination of the entire record before us, we
find that petitioners have failed to establish error in respon-
dent’s determinations that they are liable for each year at issue
for the accuracy-related penalty under section 6662(a).
We have considered all of the contentions and arguments of
the parties that are not discussed herein, and we find them to be
without merit and/or irrelevant.
To reflect the foregoing, the concessions of respondent, and
the matters abandoned by petitioners,
Decision will be entered under
Rule 155.
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