- 37 -
$191,637. Petitioners have conceded $174,030 of the proposed
adjusted capital gain of $213,993. Petitioners have also
conceded the remaining adjustments. However, respondent contends
that petitioners were negligent with respect to the depreciation
deductions. Consequently, respondent asserts that the
underpayment due to negligence was $53,452, out of the total
underpayment of $124,324.6
Petitioners contend that they reasonably relied on the
advice, expertise, and knowledge of their accountant. However,
petitioners have not presented specific evidence that reliance on
their accountant, under the circumstances, was reasonable. Thus,
petitioners are liable for the accuracy-related penalty pursuant
to section 6662(a).
Decision will be entered under
Rule 155 in docket No. 6105-93.
Decision will be entered for
petitioner in docket No. 6106-93.
6 The issues related to the remaining underpayments of
$70,872 have been resolved.
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