Stewart and Shirley Oatman - Page 10

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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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