G. Kierstead Family Holdings Trust, et al. - Page 7

               Because petitioners failed to prove they reasonably relied             
          on a competent tax professional, and because they failed to                 
          assert any other basis for relief, we hold that petitioners                 
          failed to prove that they had reasonable cause within the meaning           
          of section 6664(c).  Therefore, we find petitioners are liable              
          for accuracy-related penalties under section 6662(a) for the                
          years at issue.                                                             
               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                 
                                        under Rule 155 in docket No.                  
                                             Decisions will be entered for            
                                        petitioners in docket Nos. 24183-05           
                                        and 24185-05.                                 

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