- 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