Richard D. Irving and Cynthia A. Burrough Irving - Page 16

                                       - 16 -                                         
          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.                          


























Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  

Last modified: May 25, 2011