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hardship, but challenges based on equity have been
uniformly rejected. * * *
* * * it “is not a feasible judicial undertaking
to achieve global equity in taxation * * *. And if it
were a feasible judicial undertaking, it still would
not be a proper one, equity in taxation being a
political rather than a jural concept.” * * * the
solution must be with Congress.
Speltz v. Commissioner, 124 T.C. 165, 176 (2005) (quoting Kenseth
v. Commissioner, 259 F.3d 881, 885 (7th Cir. 2001), affg. 114
T.C. 399 (2000)), affd. 454 F.3d 782 (8th Cir. 2006); see also
Alexander v. IRS, 72 F.3d 938 (1st Cir. 1995); Okin v.
Commissioner, 808 F.2d 1338 (9th Cir. 1987), affg. T.C. Memo.
1985-199; Warfield v. Commissioner, 84 T.C. 179 (1985);
Huntsberry v. Commissioner, 83 T.C. 742, 747-753 (1984).
Petitioners’ equity argument offers no relief from the accuracy-
related penalty.
For the above-stated reasons, we find petitioners are liable
for an accuracy-related penalty under section 6662(a) of $4,837.
In reaching our holdings, we have considered all arguments
made, and, to the extent not mentioned, we conclude that they are
moot, irrelevant, or without merit.
To reflect the foregoing,
Decision will be entered
for respondent.
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