- 23 -
negligence or disregard of rules or regulations. Petitioners
have not presented any explanation for their failure to comply
with the Code and regulations regarding their rental loss. The
burden rests with petitioner to prove that respondent's
determination was in error. Rule 142(a). We therefore sustain
respondent's determination of the accuracy-related penalty with
respect to any underpayment of tax resulting from the
disallowance of petitioners' rental loss. To reflect the
foregoing,
Decision will be entered
under Rule 155.
Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Last modified: May 25, 2011