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that respondent has produced sufficient evidence to show that the
section 6662 accuracy-related penalty is appropriate. Nothing in
the record indicates petitioners acted with reasonable cause and
in good faith. The Court holds that the record supports
respondent's determination that petitioners are liable for the
accuracy-related penalty.
Reviewed and adopted as the report of the Small Tax Case
Division.
To reflect the foregoing,
Decision will be
entered for respondent.
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Last modified: May 25, 2011