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We conclude that petitioners are liable for the accuracy-
related penalty under section 6662 because they have neither
contended nor offered evidence to show that they are not so
liable. Rule 34(b)(4).
To reflect the foregoing,
Decision will be
entered under Rule 155.
4(...continued)
to challenge (and we deem them to have conceded) the accuracy-
related penalty. See Funk v. Commissioner, 123 T.C. __, __
(2004) (slip op. p. 9); Swain v. Commissioner, 118 T.C. 358, 364-
365 (2002); Jarvis v. Commissioner, 78 T.C. 646, 658 n.19 (1982).
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