- 53 - 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).Page: Previous 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 Next
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