World of Service, Inc. - Page 21

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           corporation to give corporate funds to the shareholder's                   
           friend(s) from whom they would not seek formal collection, it              
           is difficult to find that there was a true debtor-creditor                 
           relationship.  Just as significantly, petitioners have failed              
           to show that the advances were worthless during the years the              
           bad debt deductions were claimed.                                          
             Respondent determined additions to tax under section                     
           6653(a)(1) and (2) and section 6661 for each taxable year in               
           issue.  Section 6653(a)(1) provides for a 5-percent addition on            
           the entire underpayment if any part of the underpayment is due             
           to negligence or intentional disregard of rules or regulations.            
           Section 6653(a)(2) provides for an additional amount equal to              
           50 percent of the interest payable with respect to the portion             
           of the underpayment attributable to negligence.                            
             Negligence is the lack of due care or failure to do what a               
           reasonable and ordinarily prudent person would do under the                
           circumstances.  Neely v. Commissioner, 85 T.C. 934, 937 (1985).            
           Petitioners have the burden of showing that their underpayment             
           was not due to negligence or intentional disregard of rules or             
           regulations.  Rule 142(a); Welch v. Helvering, 290 U.S. 111                
           (1933); Bixby v. Commissioner, 58 T.C. 757, 791-792 (1972).                
             Both petitioners failed to maintain adequate records.  The               
           failure to properly segregate personal and business                        
           expenditures and the method of yearend allocation further                  
           exacerbate the inadequacy of petitioners' records.  It was the             




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