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professional, they do establish that petitioners made an honest
effort to comply with the substantiation requirements and assess
their proper tax liability. Petitioners have shown reasonable
cause for the underpayment and demonstrated that they were
acting in good faith. Accordingly, we conclude that petitioners
are not liable for the accuracy-related penalty under section
6662(a).
Reviewed and adopted as the report of the Small Tax Case
Division.
To reflect the foregoing,
Decision will be entered
for respondent as to the
deficiency and for petitioners as
to the accuracy-related penalty
under section 6662(a).
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Last modified: May 25, 2011