- 22 -
establish their position with respect to any of the issues
presented.
On the record before us, we find that petitioners have
failed to carry their burden of showing that they were not
negligent and did not disregard rules or regulations, or other-
wise did what a reasonable person would do, with respect to the
underpayment for each of the years at issue.
On that record, we further find that petitioners have
failed to carry their burden of showing that there was reasonable
cause for, and that they acted in good faith with respect to, the
underpayment for each of the years at issue.
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 tax years
at issue for the accuracy-related penalty under section 6662(a).
We have considered all of petitioners’ contentions and
arguments 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.
Page: Previous 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22
Last modified: November 10, 2007