- 12 -- 12 -
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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Last modified: May 25, 2011