- 11 - Commissioner, T.C. Memo. 1989-568. We disagree with petitioners that they had any such misunderstanding of fact sufficient to be a defense to the accuracy-related penalty under section 6662(h). In addition to the fact that the record is devoid of any evidence establishing that petitioners relied on Bales in investing in TBS 90-1 and claiming the purported loss for 1992 flowing therefrom, the case of Bales involved different participants, different partnerships, and different years. See Hansen v. Commissioner, 471 F.3d at 1032-1033; Mortensen v. Commissioner, 440 F.3d 375, 391-392 (6th Cir. 2006), affg. T.C. Memo. 2004-279; Sanders v. Commissioner, T.C. Memo. 2005-163. 5. Conclusion We conclude that petitioners are liable for the section 6662(h) accuracy-related penalty for 1992, as determined by respondent. See McDonough v. Commissioner, T.C. Memo. 2007-101. We have considered all arguments made by petitioners for a contrary holding, and we conclude that any argument not discussed herein is either irrelevant or without merit. An appropriate order and decision will be entered.Page: Previous 1 2 3 4 5 6 7 8 9 10 11Last modified: November 10, 2007