- 17 -
6664(c)(1).
Based upon our examination of the entire record before us,
we find that petitioners have failed to carry their burden of
establishing that they are not liable for each of the years at
issue for the accuracy-related penalty under section 6662(a).
We have considered all of the contentions and arguments of
the parties that are not discussed herein, and we find them to be
without merit, irrelevant, and/or moot.
To reflect the foregoing and the concessions of respondent,
Decision will be entered under
Rule 155.
12(...continued)
1.6664-4(b)(1), Income Tax Regs.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17
Last modified: May 25, 2011