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We find that petitioners are liable for the section 6662(a)
accuracy-related penalty for 1992. Petitioners failed to
substantiate the cost of goods sold claimed on the Schedule C and
claimed trade or business expense deductions for expenditures
that were personal in nature. Petitioners failed to offer any
reasonable explanation for the errors made on their 1992 Federal
income tax return. Petitioner's testimony was vague and often
times inconsistent with respect to many of the deductions here in
dispute.
Respondent's determination with respect to the imposition of
the section 6662(a) penalty 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, 290 U.S. 111, 115 (1933); Bixby v.
Commissioner, 58 T.C. 757, 791-792 (1972). This they have failed
to do. Accordingly, petitioners are liable for the section
6662(a) accuracy-related penalty for 1992.
To reflect the foregoing and concessions by respondent,
Decision will be entered
under Rule 155.
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