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Under the circumstances, we find that petitioners’
underpayments of Federal income taxes for 1999 and 2000 were due
to negligence and that petitioners are liable for the section
6662(a) negligence penalty for 1999 and 2000 with respect to the
adjustments relating to the three trusts, to the gain on the sale
of petitioners’ residence, and to the donation of the van.
We have considered all arguments made herein, and, to the
extent not addressed, we conclude that they are without merit or
are irrelevant.
To reflect the foregoing,
Decisions will be entered
under Rule 155.
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