- 61 - 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.Page: Previous 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61
Last modified: May 25, 2011