- 14 - that 414 and 414-1/2 Monroe were both being treated as rental properties, a cursory review of the returns would have provided petitioners with such knowledge. Line 1A of Schedule E, Supplemental Income and Loss, on the 1990 and 1991 returns and line 1B of Schedule E, Supplemental Income and Loss, on the 1992 return clearly state “DUPLEX - 414 & 414.5 MONROE ST” as the kind and location of petitioners’ rental real estate property. A review of the returns in question would have also shown the duplicate deductions taken in 1990 for mortgage interest and in 1990 and 1991 for real estate taxes. Failure to review the returns prepared for them by another is itself negligence. Metra Chem Corp. v. Commissioner, supra at 662; Bailey v. Commissioner, 21 T.C. 678, 687 (1954). Petitioners have not established reasonable cause or good faith reliance to excuse themselves from the penalties for negligence or intentional disregard of rules or regulations. See Mack v. Commissioner, T.C. Memo. 1995-482. To reflect the foregoing and 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
Last modified: May 25, 2011