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good faith for purposes of section 6664(c)(1). Accordingly, we
hold that petitioners are not liable for section 6662 accuracy-
related penalties with respect to their 2000 and 2001 tax years.
To summarize, we hold that petitioners are liable for a
deficiency of $32,133 with respect to their 2000 tax year and a
deficiency of $43,431.65 with respect to their 2001 tax year.
However, we hold that petitioners are not liable for the addition
to tax and accuracy-related penalties determined by respondent.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011