Kai-Chung C. and Meekhing T. Lam - Page 16

                                        -16-                                          
          knowledgeable and experienced businessman.  He is a certified               
          financial planner, runs his own businesses, and prepared                    
          petitioners’ returns, which included detailed depreciation                  
          schedules.  Despite this, petitioners claimed deductions for                
          hundreds of thousands of dollars of business expenses, none of              
          which they could substantiate.  Petitioners failed to convince              
          the Court they took the requisite effort to determine their                 
          proper tax liability considering petitioner’s knowledge and                 
          experience.  We find that petitioners did not prove that the                
          underpayments of income tax for the years at issue were due to              
          reasonable cause and that they acted in good faith.  Accordingly,           
          we conclude that petitioners are liable for the accuracy-related            
          penalty for each of the years at issue.                                     
               To reflect the foregoing and the concessions of the                    
          parties,                                                                    

                                                  Decision will be entered            
                                             under Rule 155.                          

















Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  

Last modified: May 25, 2011