- 26 -
We conclude that the underpayment generated by petitioner’s
erroneous items is $581 and the penalty allocated to petitioner
is $116 ($581 x 0.20).
D. Conclusion
We hold that pursuant to section 6015(c) petitioner remains
jointly and severally liable for $2,745 of the deficiency and
$116 of the accuracy-related penalty under section 6662.
In accordance with the above,
An appropriate decision
will be entered.
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