Frederick G. Harrison, Sr. and Estate of Catherine Harrison, Deceased - Page 23

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          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.                          



























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