- 6 - for the taxable year 1991. Rule 142(a). Based upon the testimony elicited from petitioner at trial, we find that respondent has met her burden of demonstrating that the $3,000 business loss deduction claimed for 1991 on the "Horizon America" Schedule C was duplicative of the business loss deduction claimed for 1990. Respondent's determination of an increased deficiency is therefore sustained. Refund and interest Petitioners failed to produce any evidence to refute respondent's determination that petitioner received taxable interest income in the amount of $369 and a $184 taxable refund from the State of Arizona during the taxable year 1991. Accordingly, respondent is sustained on these issues. Section 6662 penalty Respondent determined an accuracy-related penalty under section 6662(a) with respect to petitioners' 1990 Federal income tax return for negligence or disregard of rules or regulations. In pertinent part, section 6662 imposes an accuracy-related penalty equal to 20 percent of the portion of an underpayment of tax that is attributable to negligence or disregard of rules or regulations. Sec. 6662(a), (c). Section 6662(c) defines "negligence" as including any failure to make a reasonable attempt to comply with the provisions of the Internal Revenue Code, and defines "disregard" as including any careless, reckless, or intentional disregard.Page: Previous 1 2 3 4 5 6 7 Next
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