- 31 - that, with some assiduous efforts, petitioners could have re- sorted the records at least into their original state. We are unmoved by petitioner’s explanation that he trusted his father and signed anything that Jack put in front of him. Although petitioner lacks higher education, we believe that he was aware of his responsibility to report his income accurately. He did not do so. Accordingly, we conclude that petitioners’ underpayments are attributable to negligence or disregard of rules or regulations. Thus, we hold that petitioners are liable for accuracy-related penalties under section 6662(a) for 1993 and 1995, based on the amount of their underpayments for those years, to be determined in the Rule 155 computations. To reflect the foregoing and the parties’ concessions, Decision will be entered under Rule 155.Page: Previous 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31
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