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substantiated. They blindly accepted Mr. Beltran's
representations and took no steps to ascertain whether such
representations were correct. The Court concludes that
petitioners made no effort to ascertain their correct tax
liability for the years in question. Therefore, the Court
sustains respondent on the accuracy-related penalties under
section 6662(a).
Reviewed and adopted as the report of the Small Tax Case
Division.
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011