John K. Jorman, Jr. and Audrey Jorman - Page 10

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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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