Howard J. Kaplan and Brenda L. Kaplan, et al. - Page 53

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          that he believed that claiming a deduction with respect to such             
          claimed charitable contribution would be a “push”; that is to               
          say, Mr. Marceron believed that there was a substantial risk that           
          respondent would disallow any such claimed deduction.                       
               On the record before us, we find that petitioners in each of           
          these cases have failed to carry their burden of establishing               
          that there was reasonable cause for, and that they acted in good            
          faith with respect to, any portion of the underpayments in                  
          petitioners’ respective returns for 1999.                                   
               Based upon our examination of the entire record before us,             
          we find that petitioners in each of these cases have failed to              
          carry their burden of establishing that they are not liable for             
          1999 for the accuracy-related penalty under section 6662(a)                 
          because of a substantial understatement of tax under sec.                   
          6662(b)(2).26                                                               
               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.                                     






               26In light of our finding under sec. 6662(a) and (b)(2), we            
          need not address respondent’s argument that petitioners in each             
          of these cases are liable for 1999 for the accuracy-related                 
          penalty under sec. 6662(a) because of negligence or disregard of            
          rules or regulations under sec. 6662(b)(1).                                 





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