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attempt to comply with the statute, and the term "disregard"
includes any careless, reckless, or intentional disregard. Sec.
6662(c). Respondent's determination is presumed correct, and
petitioners bear the burden of proving that they are not liable
for the accuracy-related penalty under section 6662(a). Rule
142(a); Welch v. Helvering, supra at 115 (1933); Bixby v.
Commissioner, 58 T.C. 757, 791-792 (1972).
Petitioners produced little substantiating evidence in
support of the moving expense deduction in dispute in this
matter. Furthermore, they failed to explain why all but one of
the components of the deduction were in excess of what
substantiating evidence they did produce. Likewise, petitioners
produced substantiating evidence for only a small portion of the
deductions claimed on the Schedule C. Had we resolved the trade
or business issue in favor of petitioners, most of the deductions
would have been denied for lack of substantiation anyway. Given
petitioners' prior experience in this Court, they were no doubt
aware that the production of substantiating evidence was expected
and necessary to support their claimed entitlement to the
deductions in dispute. We can only conclude that their failure
to produce substantiating evidence results from their failure to
have maintained adequate books and records as required by section
6001 and the corresponding regulation. In our view, petitioners'
failure to explain the excessive deductions claimed along with
their recordkeeping deficiencies constitute at least a careless
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