Timothy A. Runels and Emma Valdivieso Runels, et al. - Page 20




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          they were not entitled and had underreported gross receipts from            
          their pallet business.  For 2004, petitioners failed to report              
          capital gains and dividends, the only adjustments to which the              
          penalty was applied.  The Court concludes that respondent has               
          produced sufficient evidence to show that the accuracy-related              
          penalties under section 6662 are appropriate.                               
               Petitioners have not shown that their underreporting of                
          income and overreporting of deductions were actions taken with              
          reasonable cause and in good faith.  Respondent’s determinations            
          of accuracy-related penalties under section 6662(a) for 2002,               
          2003, and 2004 are sustained.                                               
               To reflect the foregoing,                                              
                                                  Decisions will be entered           
                                             under Rule 155.                          























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