Gregory C. and Phyllis Lam - Page 7

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          there was a reasonable cause for such portion and that the                  
          taxpayer acted in good faith with respect to such portion.  Sec.            
               On this record, we conclude that petitioners are liable for            
          the accuracy-related penalty under section 6662(a) as imposed by            
          respondent.  Petitioners have failed to provide any reasonable              
          explanation or credible evidence to substantiate entitlement to             
          the claimed deductions.  Such actions are not those of a                    
          reasonable and prudent person under the circumstances.                      
               Reviewed and adopted as the report of the Small Tax Case               

                                                  Decision will be entered            
                                             for respondent.                          

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Last modified: May 25, 2011