Manuel Francisco Palomo and Jane Lyon Potter - Page 13

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                    return.  Further, petitioners failed to produce any evidence to                                                                                        
                    show that they acted with reasonable cause and good faith for the                                                                                      
                    year at issue.  Thus, the Court sustains respondent's                                                                                                  
                    determination that petitioners are liable for the accuracy-                                                                                            
                    related penalty under section 6662(a) for 1999.                                                                                                        
                              Reviewed and adopted as the report of the Small Tax Case                                                                                     
                    Division.                                                                                                                                              
                                                                                          Decision will be entered                                                         
                                                                                under Rule 155.                                                                            































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