Charles M. Fatta and Mary T. Oleske - Page 8




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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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