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between taxpayers and the Commissioner involving whether certain
activities constituted trades or businesses for purposes of
section 162(a). In resolving such disputes we are required to
focus upon the nature of the activity involved. Needless to say,
before we can determine whether an activity constitutes a trade
or business, we must know what the activity is. In this case, we
have no idea what petitioner's real-estate-related activity was
in 1991. Without knowing the nature and the extent of the
underlying activity, we cannot determine whether such activity
was conducted by petitioner regularly and with continuity with
the primary purpose of earning a profit. Absent such findings
we are unable to conclude that petitioner was engaged in a real-
estate-related trade or business during 1991. See Commissioner
v. Groetzinger, 480 U.S. 23, 35 (1987). Because petitioner has
failed to meet his burden of proving that the deductions in
dispute relate to expenses paid or incurred in connection with an
activity that constitutes a trade or business, respondent's
adjustments disallowing the deductions are sustained.
Accuracy-Related Penalty
Respondent determined that petitioners were liable for the
accuracy-related penalty pursuant to section 6662(a) in the
amount of $1,268 for the year 1991. Section 6662(a) and (b)(1)
imposes a penalty on any portion of an underpayment which is
attributable to negligence or disregard of rules or regulations.
The term "negligence" includes any failure to make a reasonable
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