-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.
24184-05.
Decisions will be entered for
petitioners in docket Nos. 24183-05
and 24185-05.
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Last modified: November 10, 2007