- 10 - 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).Page: Previous 1 2 3 4 5 6 7 8 9 10
Last modified: May 25, 2011