Delaware Corp., et al. - Page 58

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          section 6662(a).22                                                          
               We have considered all of the contentions and arguments of             
          the parties that are not discussed herein, and we find them to be           
          without merit, irrelevant, and/or moot.                                     
               To reflect the foregoing and the concessions of Delaware               
          Corporation,                                                                
                                             Decisions will be entered                
                                        for respondent.                               





















               22We have found that petitioners are liable for the years at           
          issue for the accuracy-related penalties at issue because of                
          negligence or disregard of rules or regulations under sec.                  
          6662(b)(1).  In light of that finding, we shall not address                 
          respondent’s alternative argument that petitioners are liable for           
          the years at issue for those accuracy-related penalties because             
          of substantial understatements of income tax under sec.                     
          6662(b)(2).                                                                 

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