- 10 -
Petitioners did not address the accuracy-related penalties
at trial. Petitioners claimed double deductions for the same
expenses, moving expenses when they never moved, a capital loss
when no such loss occurred, Schedule C and Schedule E deductions
for which they kept no decipherable records, and foreign earned
income exclusions for which they did not qualify. Nothing in the
record establishes that petitioners had reasonable cause to claim
these deductions and exclusions, and we are not persuaded
petitioners acted in good faith. Petitioners therefore are
liable for the accuracy-related penalties as determined by
respondent.
To reflect the foregoing,
Decision will be entered
for respondent.
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Last modified: May 25, 2011