- 28 - 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.Page: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
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