- 32 -
underpayment for any of the years at issue.18 On that record, we
further 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 any of the years at issue. See
sec. 6664(c).
We have considered all of the contentions and arguments of
petitioners that are not discussed herein, and we find them to be
without merit and/or irrelevant.
To reflect the foregoing and the concessions of respondent,
Decision will be entered
under Rule 155.
18In the notice, respondent determined that petitioners are
liable for each of the years at issue for the accuracy-related
penalty under sec. 6662(a) on the alternative ground that there
was a substantial understatement of income tax under sec.
6662(b)(2). We have found that petitioners are liable for each
of the years at issue for the accuracy-related penalty because of
negligence or disregard of rules or regulations under sec.
6662(b)(1). In light of that finding, we shall not address
whether petitioners are liable for each of the years at issue for
the accuracy-related penalty because of a substantial understate-
ment of income tax under sec. 6662(b)(2).
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