Herbert Donald Singer - Page 21

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               In view of the foregoing, we hold that petitioner is liable            
          for the accuracy-related penalty under section 6662(a) for each             
          of the years in issue.                                                      
          E.  Conclusion                                                              
               Reviewed and adopted as the report of the Small Tax Case               
          Division.                                                                   
               To reflect our disposition of the disputed issues, as well             
          as respondent’s concession, see supra note 2,                               


                                                  Decision will be entered            
                                             under Rule 155.                          


















               11(...continued)                                                       
          (distilling truth from the testimony of witnesses, whose demeanor           
          we observe and whose credibility we evaluate, is “the daily grist           
          of judicial life”); Kropp v. Commissioner, T.C. Memo. 2000-148              
          (“As a trier of fact, it is our duty to listen to the testimony,            
          observe the demeanor of the witnesses, weigh the evidence, and              
          determine what we believe.”).                                               

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