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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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Last modified: March 27, 2008