- 16 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16
Last modified: May 25, 2011