World of Service, Inc. - Page 22

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           Johnsons' and petitioners' choice to mix personal and business             
           records, and their failure or inability to properly show the               
           division is of their own making and was clearly negligent.                 
           Stovall v. Commissioner, 762 F.2d 891, 895 (11th Cir. 1985),               
           affg. T.C. Memo. 1983-450; Crocker v. Commissioner, 92 T.C.                
           899, 917 (1989).                                                           
             Further, petitioners claimed, up until the eve of trial,                 
           amounts which had been conceded in prior proceedings.  Claiming            
           hundreds of thousands of dollars in net operating loss                     
           deductions, when those matters had been finally settled in                 
           earlier years' litigation, cannot be considered reasonable or              
           what an ordinarily prudent person would do.  Although                      
           petitioners' returns were prepared by accountants, the Johnsons            
           made all judgments regarding personal or business decisions,               
           and they labeled various amounts for inclusion in the corporate            
           returns.  We also note that Mr. Johnson has an associate's                 
           degree in tax and accounting.                                              
             Under these circumstances, petitioners have failed to show               
           that respondent's determination was in error; hence, we find               
           that petitioners are liable for additions to tax under section             
           6653(a)(1) and (2).                                                        
             Respondent determined that petitioners are liable for an                 
           addition to tax under section 6661 for all taxable years in                
           dispute.  Section 6661(a) provides for an addition to tax in               
           the amount of 25 percent of any underpayment attributable to a             




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